MiCAR Transitional Period Ends July 1, 2026: What CASPs Must Do Now

The Markets in Crypto-Assets Regulation (MiCAR) transitional period closes on July 1, 2026. After that date, all crypto-asset service providers (CASPs) operating in the European Union must hold full MiCAR authorisation. Operating without it constitutes a regulatory breach.

This is not a soft deadline. National competent authorities (NCAs) across EU member states have been processing authorisation applications since December 2024. The transitional period was introduced precisely to give existing CASPs time to achieve compliance — that time is now exhausted.

What the transitional period was

When MiCAR came into full effect in December 2024, CASPs that were already regulated under national crypto-asset frameworks — such as Germany's BaFin crypto custody licence, France's PSAN registration, or similar national regimes — were permitted to continue operating under those national licences for up to 18 months. That window expires on July 1, 2026.

CASPs that relied on this transitional provision and have not yet submitted a complete MiCAR authorisation application are now in a difficult position.

What full MiCAR authorisation requires

To hold a MiCAR authorisation, a CASP must demonstrate compliance with Title V of Regulation (EU) 2023/1114 across several areas:

Governance and management

• Fit and proper management body with appropriate crypto-asset expertise
• Clear organisational structure, reporting lines, and internal controls
• Written policies on conflicts of interest, complaints handling, and outsourcing

Capital requirements

• Minimum own funds: €50,000 (Class 1), €125,000 (Class 2), or €150,000 (Class 3), depending on services provided
• Own funds must be maintained on an ongoing basis and reported quarterly

Custody and safekeeping

• Segregation of client assets from own assets
• Written custody policy with defined safekeeping procedures
• Business continuity plan specific to custody interruption

Market abuse framework

• Written policies for detecting and preventing market manipulation and insider trading
• Designated market abuse officer and internal reporting procedures

Passporting and reverse solicitation

• If operating across multiple EU member states: either establish local presence or apply for a MiCAR passport via the home NCA
• Reverse solicitation is defined narrowly — it cannot substitute for authorisation

Where NCAs currently stand

As of June 2026, the ESMA CASP Register lists approximately 200 entities with confirmed MiCAR authorisation or in-process status. The distribution is uneven:

• Germany, France, Ireland, and Luxembourg have processed the most applications
• Several southern and eastern EU member states are still building out their supervisory infrastructure
• Processing times range from 3 to 9 months depending on the NCA and application completeness

CASPs that submitted applications before April 2026 may still be processing. However, operating in an unauthorised state after July 1, 2026 exposes the firm to enforcement action from the NCA, regardless of pending status.

The compliance officer's immediate checklist

If you are the compliance officer at a CASP facing this deadline, the following actions are non-negotiable:

1. Confirm application status — contact your NCA to obtain written confirmation of where your application sits in the queue
2. Document your transitional period entitlement — ensure you have a clear paper trail showing you were registered under a national regime before December 2024
3. Identify the gap — compare your current operational policies against MiCAR Title V requirements and document any gaps with a remediation timeline
4. Prepare the management body — at least one member of the management body must demonstrate crypto-asset expertise; regulators are examining this closely
5. Brief your board — the board must understand MiCAR obligations; demonstrable board-level engagement is required for authorisation

What the GENIUS Act means for dual-jurisdiction firms

For CASPs with US operations, the GENIUS Act adds a parallel stablecoin compliance layer. The Act defines "permitted payment stablecoin issuers" (PPSIs) and imposes reserve, redemption, and reporting requirements distinct from MiCAR. Firms operating in both jurisdictions need compliance officers who understand both regimes simultaneously.

CARCI's MiCAR Specialist programme

The CARCI MiCAR Specialist programme is an 80-hour, examination-assessed professional certification covering the full MiCAR regulatory architecture. It is structured for compliance officers, legal counsel, and CASP management preparing for authorisation.

Completion earns a verifiable professional designation. Current cohort enrolments close June 30, 2026.

Enrol in MiCAR Specialist →

CARCI Intelligence is produced by practitioner faculty with direct experience in MiCAR implementation. This article is for professional information purposes only and does not constitute legal advice.