Since the EU-wide transition ended on 1 July 2026, a crypto-asset service provider serving customers in Germany generally needs MiCA authorisation to provide covered services—or must qualify for a specific route for certain already-regulated financial entities. An old German licence, a pending application, or a familiar exchange brand is not proof of MiCA authorisation. Customers should check the provider’s legal entity and authorised services in official registers, then understand how it safeguards client assets. Authorisation imposes regulatory duties; it does not guarantee crypto’s value or eliminate the risk of provider failure.
What MiCA authorisation means
The EU Markets in Crypto-Assets Regulation (MiCA) generally bars a crypto-asset service provider (CASP) from providing covered services in the Union unless it is authorised under Article 63 or can use the Article 60 route available to specified regulated financial entities. The requirement concerns the provider and the services it offers—not whether a particular token is a sound investment. MiCA, Article 59
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Covered services include custody and administration, operating a trading platform, exchanging crypto-assets for funds or other crypto-assets, advice, portfolio management, and transfer services. A platform’s authorisation should therefore be checked against the service you actually use, rather than treated as a blanket approval of every product or activity associated with its brand.
How to check whether an exchange is authorised in Germany
- Find the legal entity. Check the exchange’s terms, account documents, or other legal information to identify the company providing your service. A brand name alone may not identify the regulated provider.
- Search official registers. BaFin says granted German authorisations are published in the Federal Gazette, BaFin’s company database, and ESMA’s interim register. Look up the legal entity, not just the trading name. BaFin’s MiCA authorisation information
- Confirm the service and status. Check that the register entry concerns the relevant entity and covers the service you intend to use. An application in progress, historical national status, or marketing claim is not the same as a granted MiCA authorisation.
- Check cross-border notification where relevant. A provider authorised in one EU country can offer services in another after completing the required notification. A German-language website or access from Germany does not, by itself, establish that a provider is authorised or properly passported. BaFin’s information on authorisation and passporting
Register entries and regulatory guidance can change. Check the current official entry when choosing a provider or responding to a status change.
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Why an old licence or pending application is not enough
MiCA allowed qualifying providers that had offered services in accordance with applicable law before 30 December 2024 to continue temporarily under national arrangements. Member States could shorten that transition or decline to apply it; in any case, the EU-wide maximum end date was 1 July 2026. A provider whose application was refused or that had not obtained authorisation by the applicable transition deadline had to stop providing the relevant services until authorised. MiCA, Article 143
ESMA stated on 23 June 2026 that the EU transition would expire on 1 July 2026 and that unauthorised providers should cease providing services after it ended. The transition was not MiCA authorisation: a provider relying on grandfathering was not yet an authorised CASP under MiCA. As of the transition’s end, “we are applying” should not be treated as permission to continue offering covered services. ESMA’s 23 June 2026 statement · ESMA Q&A 2220 · ESMA Q&A 2295
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What customers should do if their provider is not authorised
ESMA advises customers to check the provider in its register and act promptly if it is not authorised. Its suggested options include transferring crypto-assets to an authorised CASP, if one is identified, or to a self-hosted wallet. This is general supervisory guidance, not personal legal or investment advice. Whether a transfer is possible, and what steps or deadlines apply, depend on the provider and the customer’s circumstances. ESMA’s consumer guidance
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With a self-hosted wallet, control and recovery responsibilities shift to you. You must protect the credentials or recovery information needed to access the assets. A self-hosted wallet is an option, not a MiCA requirement, and moving assets does not remove the risks of price changes, loss of access, or mistakes during a transfer.
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What MiCA requires for client assets—and what it does not promise
Under Article 70, a CASP that holds client crypto-assets or the means of access to them must make adequate arrangements to safeguard clients’ ownership rights, particularly in insolvency, and prevent the provider from using client crypto-assets for its own account. Where its business model requires holding client funds, the article also requires safeguarding arrangements for those funds. MiCA, Article 70
These obligations are not a guarantee that customers will recover everything if a provider fails. Nor do they insure a token against a fall in market value, make crypto-assets bank deposits, or prevent cyber incidents and every form of fraud. Authorisation is a regulatory status with associated duties and supervision, not a promise of safety or investment performance.
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What to compare between providers
- Register status: Does the exact legal entity appear as authorised in an official register?
- Service scope: Does its authorisation cover the activity you plan to use, such as custody, exchange, or trading-platform operation?
- Asset arrangements: What does the provider disclose about custody and safeguarding client assets?
- Continuity plans: If its status changes, how does it explain client migration, withdrawals, or an orderly wind-down?
- Location and passporting: Where is the provider authorised, and has it completed the notification needed to offer services cross-border?
Authorisation can help you assess whether a provider is operating within MiCA’s framework. It is not a regulator’s endorsement of the exchange, its products, or the assets available on it.
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