On 1 July 2026, the final transitional period under the Markets in Crypto-Assets Regulation (MiCA) expired across the European Union. Under Article 143(3) of Regulation (EU) 2023/1114, Member States could extend grandfathering only until that date, and the Regulation provides no mechanism for a further extension. From then on, providing regulated crypto-asset services to EU clients without a CASP authorisation falls outside the MiCA framework. For companies that missed the deadline, four realistic options remain: submit a late application, operate through a licensed partner, acquire an authorised CASP or refocus on markets outside the EU.
#MiCA Grandfathering Deadline: What Changed on 1 July 2026
MiCA's grandfathering regime allowed crypto businesses that were lawfully operating before 30 December 2024 to continue providing services while preparing their CASP applications. However, that relief was temporary. Under Article 143(3) of MiCA, all transitional arrangements had to end by 1 July 2026. Several Member States closed their windows much earlier, including the Netherlands, Poland, Latvia, Hungary and Slovenia during 2025, while Germany and Ireland also ended their transitional periods before the EU-wide deadline. As of 1 July, no grandfathering regimes remain in force. Importantly, a submitted application is not an authorisation. According to ESMA, only an approved CASP licence permits regulated activity after the transitional period has ended.
#MiCA-Authorised CASPs: What the ESMA Register Shows
Before MiCA, Europe had a fragmented system of national crypto registrations. According to TRM Labs, more than 3,000 registrations existed, although only around 1,100–1,300 providers were actively offering crypto services. MiCA replaces those national regimes with a single authorisation framework, and the ESMA Register of Crypto-Asset Service Providers is now the primary public record of authorised firms. As of 14th July, the register lists 283 authorised CASPs. The comparison shows that only around one-fifth of the previously active market has completed the transition, making ESMA's register an increasingly important reference point for banks, business partners and customers.
#How This Affects Crypto Exchanges and Custodians
The end of grandfathering affects a broad range of crypto businesses, including exchanges, trading platforms, custodians, brokers, firms executing or transmitting crypto-asset orders, transfer service providers, portfolio managers and advisers. MiCA applies according to where the service is provided, not simply where a company is incorporated.
Businesses established outside the EU that actively target or continue serving EU clients generally require a CASP authorisation, typically through an authorised EU entity. Reverse solicitation remains a narrow legal exception rather than a growth strategy and may not apply where firms actively market to European customers. For companies outside the ESMA register, the immediate question is no longer whether MiCA applies, but which compliance route offers the most practical path forward.
#Option 1 — File a Late Application
Missing the 1 July 2026 deadline does not prevent a company from applying for a MiCA CASP licence. National competent authorities continue to accept applications, but a late application does not restore the right to operate in the EU. Until authorisation is formally granted, regulated crypto-asset services must not be provided to EU clients.
ESMA has also indicated that supervisors are expected to apply increased scrutiny to firms that delayed seeking authorisation after the end of the transitional period. In practice, obtaining a CASP licence is measured in months rather than weeks. During that period, businesses typically suspend regulated EU activities or operate through another compliant structure.
Companies preparing their documentation may find our guide to building a CASP licence business plan under MiCA useful when structuring their application. Those still choosing where to file can start with our Cyprus CASP guide, which covers the requirements and timelines in one of the most commonly used filing jurisdictions.
#Option 2 — White-Label Under a Licensed CASP
For businesses that cannot suspend their European operations, partnering with an already authorised CASP may provide the only practical way to remain active while their own licensing strategy develops. Under a white-label arrangement, regulated services are delivered through the infrastructure and authorisation of an existing CASP, allowing customers to continue using the platform without a prolonged interruption.
The main advantage is business continuity, particularly where EU clients represent a significant share of revenue. However, the model also has limitations. The licensed CASP retains responsibility for regulatory compliance, meaning the partner must operate within another firm's governance framework, AML controls and commercial terms. Product flexibility may also be reduced.
For companies facing immediate commercial pressure, however, a white-label partnership can serve as an effective bridge until they receive their own MiCA authorisation — or as a long-term operating model where obtaining an independent licence is not commercially justified.
#Option 3 — Acquire an Already-Licensed Entity
For companies that cannot afford to spend several months outside the European market, acquiring an already authorised CASP may be the fastest route back into compliance. Unlike a new application, the regulatory framework, governance structure and passporting rights are already in place — the transaction focuses on transferring ownership rather than building a licensed business from scratch.
However, it is not an instant shortcut. A change in qualifying holdings normally requires approval from the competent national authority before the acquisition can be completed, and regulators assess the proposed owners' reputation, financial soundness and ability to ensure the prudent management of the licensed business. Thorough legal and commercial due diligence is equally important, as buyers inherit existing compliance obligations alongside the licence.
Businesses exploring this option can browse available licensed crypto companies on Dealable24. For additional guidance on MiCA compliance, crypto licensing and jurisdiction selection, explore our Crypto Guides. Equilex also assists clients throughout the acquisition process, including legal due diligence, transaction structuring and regulatory support during ownership approval procedures.
#Option 4 — Restructure Around Non-EU Markets
For some crypto businesses, the most commercially sensible option may be to withdraw from the EU market altogether. This involves stopping the provision of regulated crypto-asset services to EU clients, implementing appropriate geo-blocking and marketing controls, and focusing future growth on jurisdictions outside MiCA's scope.
While this is a lawful strategy, it also means giving up revenue generated from European customers. Many firms instead choose to strengthen their presence in jurisdictions such as the United Arab Emirates, Hong Kong or Singapore, depending on their target markets and business model. Others adopt a multi-jurisdiction licensing strategy to balance regional opportunities with regulatory certainty.
Businesses evaluating this approach may also find our guides to secondary licensing beyond the EU and the top countries for crypto businesses in 2026 useful when comparing alternative regulatory environments.
#How to Choose the Right Path After the MiCA Deadline
The most appropriate strategy depends on your business model, commercial priorities and the role the European market plays in your long-term growth. Companies that rely heavily on EU clients but can accommodate the licensing timeline will generally benefit from submitting a late CASP application, potentially supported by a white-label arrangement during the review period. Businesses that require uninterrupted access to the EU market may find acquiring an already authorised CASP a faster solution. Where Europe is no longer a strategic priority, restructuring around non-EU markets may offer the clearest path forward.
Although the MiCA grandfathering period ended on 1 July 2026, it did not eliminate the strategic options available to crypto businesses. Acting early preserves flexibility, while delaying key decisions can increase both compliance risk and operational disruption.
If your business is evaluating the most suitable path after the MiCA deadline, Equilex can assist with CASP licensing, acquisition of licensed entities, legal due diligence, regulatory approvals and international licensing strategies. You can also explore our crypto licensing solutions to compare available licensing opportunities across multiple jurisdictions.
#FAQ:
#Can a crypto company still apply for a MiCA licence after 1 July 2026?
Yes. Companies may continue submitting CASP applications after the end of the transitional period. However, filing an application does not authorise the business to provide regulated crypto-asset services in the EU. Operations may resume only after the competent national authority grants the CASP licence, and regulators are expected to apply greater scrutiny to late applicants.
#What happens if a CASP keeps serving EU clients without authorisation?
After the end of the transitional period, providing regulated crypto-asset services without the required authorisation breaches MiCA (Article 59). Competent national authorities may impose supervisory or enforcement measures, while banks, payment providers and commercial counterparties increasingly use the ESMA Register to verify whether a crypto business is authorised to operate.
#How does MiCA affect cryptocurrency exchanges outside the EU?
MiCA applies according to where regulated services are provided rather than where the business is incorporated. A non-EU exchange that actively targets or serves EU clients will generally require a CASP authorisation, usually through an authorised EU entity. Reverse solicitation remains a narrow exception and should not be treated as a long-term market entry strategy.
#Can Equilex help with acquiring an already-licensed CASP entity?
Yes. Equilex supports clients throughout the acquisition process, including identifying suitable licensed companies, conducting legal and regulatory due diligence, structuring the transaction and assisting with regulatory approval of changes in qualifying ownership. Where an acquisition is not the best solution, we also advise on alternative licensing jurisdictions.