MiCA: the transitional period has come to an end — what comes next for CASPs?

Today, 1 July 2026, marks the end of the MiCA transitional period. This means that only authorised crypto-asset service providers (CASPs) may provide crypto-asset services within the European Union.

1. End of the MiCA transitional period

In its latest Public Statement published on 23 June 2026, the European Securities and Markets Authority (ESMA) recalled that CASPs not authorised as of 1 July 2026 are expected to proceed with an orderly wind-down of their crypto-asset services while safeguarding clients’ interests, building on its previous statement, which we discussed in our April 2026 Newsflash.

ESMA further clarifies that, within the framework of ongoing wind-down arrangements, unauthorised CASPs must limit the provision of services to actions necessary to sell or transfer crypto-assets, reallocate assets or close positions. The custody of clients’ crypto-assets may continue only for the period strictly necessary to complete an orderly exit.

ESMA also reminds CASPs established outside the EU that they may not provide MiCA services to EU clients or solicit EU clients, except under the narrow reverse-solicitation exemption. ESMA further notes that MiCA prohibits CASPs from outsourcing or delegating certain services, notably custody, to entities that are not authorised as CASPs.

2. Luxembourg’s emerging CASP market

In Luxembourg, the end of the transitional period is also an opportunity to highlight a market that is becoming more structured and institutionally anchored. Luxembourg is well positioned in this evolving environment, with 11 entities authorised as CASPs by the Commission de Surveillance du Secteur Financier (CSSF) as of today.

Authorised CASPs in Luxembourg offer a range of crypto-asset services, from the custody and administration of crypto-assets on behalf of clients to transfer services for crypto-assets on behalf of clients. The already existing ecosystem continues to make Luxembourg an attractive hub for firms seeking to develop regulated crypto-asset activities within the European Union.

3. What comes next for CASPs?

Supervisory priorities communicated during industry events may include internal governance, in particular internal controls, ICT robustness, the overall risk management framework and the AML framework.

In the longer term, CASPs may also wish to prepare for changes to the applicable regulatory framework. Indeed, the European Commission has published a targeted consultation paper on the review of MiCA, open for replies until 31 August 2026. As a result, a revision of MiCA — namely, a possible “MiCA 2” — may be expected over the coming years, potentially bringing greater legal certainty, in particular on topics relating to yield-generating activities such as staking, lending and borrowing of crypto-assets, as well as on the currently prohibited granting of interest or any interest-equivalent remuneration on stablecoins, together with further clarity on the multi-issuance model for global tokens. Market participants may also wish to monitor possible future clarifications on the delineation between MiCA and other EU regulatory frameworks, including in particular payment services.