After 1 July 2026, a crypto-asset service provider (CASP) that lacks the required MiCA authorisation must stop providing covered services to EU clients if its transition period has ended. For users, the key question is not just whether an exchange’s brand is familiar or it applied for a licence, but whether the exact legal entity serving them is authorised. Developers and product teams should check which entity provides each service and plan for any required wind-down.
What changed after 1 July 2026?
MiCA’s transitional arrangement let qualifying providers continue under applicable national rules for a limited time. The EU-wide outside date was 1 July 2026. A provider’s transition could end sooner if it received or was refused MiCA authorisation, or if its Member State set an earlier deadline or no transition at all. As ESMA stated on 17 April 2026, “The MiCA transitional period will officially expire across the EU on 1 July 2026.”
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Once the relevant transition ended, a provider without the required authorisation had to stop offering covered crypto-asset services to EU clients. ESMA says that applies even if a Member State had not yet adjusted its national law to MiCA. A licence application still pending at the end of the applicable transition does not give the provider extra time to operate: it must stop until authorised.
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The transition was not available to every business that called itself an exchange or crypto service. The provider had to have supplied the relevant services in accordance with applicable national law before 30 December 2024. A firm that did not meet that condition, or one in a country where the transition had already expired, could not rely on the grandfathering arrangement.
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Can you still use your crypto exchange?
Possibly, but the answer depends on the provider’s authorisation and the legal entity that serves your account. If that entity is authorised for the relevant service, MiCA applies to it. If it is not authorised and its transition has ended, it must cease offering covered services to EU clients. That does not mean you personally are prohibited from holding crypto; it means you should not assume the provider can continue ordinary service or that your account has the same protections.
A brand may operate through several companies in different countries. An authorised company in the same corporate group does not automatically authorise another group company, a non-EU affiliate, or the entity named in your account terms. MiCA safeguards attach to the specific authorised EU legal entity, not to a brand as a whole.
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How to check whether your provider has a MiCA licence
- Find the contracting entity. Review your account agreement, terms of service, or other customer documents for the precise company name and jurisdiction responsible for your account and services.
- Search ESMA’s Interim MiCA Register. Match the legal entity—not just the brand—to the register record, and check that the authorisation covers the service you use.
- Read the register record with its timing caveat. ESMA said the interim register was updated on 7 October 2026 and is published weekly. Its data comes from national competent authorities and may take time to appear, so an absent or incomplete entry is a reason to verify the provider’s status with the relevant authority or provider, not proof by itself of a particular outcome.
- Check the provider’s own wind-down notice if it is unauthorised. Look for deadlines, which services will stop, how to withdraw or transfer assets, and what will happen to residual positions. ESMA expects providers to communicate these arrangements.
If the provider is unauthorised, what can you do with your assets?
ESMA identifies possible responses such as transferring assets to an authorised CASP, moving them to a self-hosted wallet, or considering closing positions. These are options, not a universal recommendation. Compare them against the provider’s actual wind-down process and your ability to complete the steps safely.
| Option | What to weigh |
|---|---|
| Transfer to an authorised CASP | You would use another service provider, subject to its asset and network support and onboarding requirements. The receiving provider must carry out required customer due diligence and other applicable AML/CFT checks. Check transfer fees, timing, and whether it supports the specific asset and network. |
| Move to a self-hosted wallet | You take custody rather than leaving the assets with a CASP. Confirm asset and network compatibility and that you can securely create and protect recovery arrangements. A hardware wallet is one optional way to support self-custody; it is not required or regulator-endorsed, and choosing a device does not by itself make a transfer safe. |
| Close positions | This may avoid arranging a transfer, but consider the provider’s stated process, timing, fees, and the consequences of selling or closing the position. It is not necessarily the right choice for every asset or user. |
ESMA expects an orderly exit with prior notice and arrangements that avoid undue economic harm. Its June 2026 statement says client communications should explain timelines for disposal, transfer, reallocation, or closure and how residual positions may be handled. Follow the provider’s instructions and deadlines while checking that you understand the practical consequences of your chosen route.
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What protections apply while you decide?
Clients using an unauthorised CASP do not benefit from MiCA safeguards, including MiCA’s client-asset protections. ESMA warns that remaining with such a provider can mean reduced legal protection and a greater risk of losing access to assets. The exact protections depend on the legal entity and service involved; a group company’s authorisation should not be treated as protection for an account held with a different entity.
What unauthorised providers are expected to do
In its 23 June 2026 statement, ESMA set out expectations for unauthorised CASPs winding down. They should stop onboarding new EU clients, opening new relationships or accounts, marketing, and soliciting business. They should limit services to what is needed to sell or transfer assets, reallocate them, or close positions. Custody should continue only for the time strictly needed to complete an orderly exit.
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Providers should communicate clearly and repeatedly, explain relevant deadlines, and maintain applicable AML/CFT controls during the wind-down. Those controls include customer due diligence, monitoring, sanctions screening, suspicious activity reporting, record keeping, and crypto-transfer traceability obligations. ESMA also expects authorised receiving CASPs to onboard migrating clients only after the required due diligence and other applicable checks.
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What developers and product teams should review
For a product team, the central task is to identify who provides each service and whether it is a regulated MiCA service—not merely to add a licence badge to an interface. A software integration alone is not automatically a regulated service; the exact role depends on the facts and requires legal analysis.
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- Map each product function to the service it enables and the legal entity responsible for providing it.
- Check whether that entity is authorised for the relevant service and geography, rather than relying on a group company’s status or a pending application.
- Define how the product responds when a provider’s transition ends or authorisation is refused, including migration, service restrictions, and account closure paths.
- Plan client notices and operational continuity for custody, transfers, records, and applicable AML/CFT controls during an exit.
- Review third-party and cross-border arrangements. ESMA says firms established outside the EU generally may not provide MiCA services to EU clients or solicit them, except under the narrow reverse-solicitation regime. It also warns that CASPs may not outsource or delegate certain services, notably custody, to entities that are not authorised CASPs.
National deadlines were not identical
1 July 2026 was the EU-wide outside limit, not a promise that every qualifying provider could operate until that date. Article 143 allowed Member States to shorten or omit the transition. ESMA’s national table lists periods from six to 18 months among the EU states and EEA countries it covers. It also includes country-specific application cutoffs and cautions that some entries reflected regulator expectations that might not yet have been incorporated into national law. For a particular provider or country, check current national law and the provider’s status rather than applying another country’s timeline.
Separate issue: EMT payments and PSD2
MiCA’s CASP transition should not be confused with the separate PSD2 question for certain electronic-money-token (EMT) transactions that qualify as payment services. The European Banking Authority’s nine-month no-action transition ended on 2 March 2026. The EBA discussed conditions under which national authorities could allow some activity to continue while PSD2 authorisation was pending, but that is not an extension of MiCA’s CASP transition. Developers handling EMT payment functionality need to assess the exact service and applicable payment-services rules separately.
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