MiCA Regulation: The 1 July 2026 Cliff and Seven CASP Activities

Most crypto compliance teams are reading the MiCA regulation as a registration deadline. It is an architectural decision. The 1 July 2026 cliff that closes Article 143 of Regulation (EU) 2023/1114 lands uniformly across the EU, and the seven crypto asset services it brings under the crypto assets regulation framework do not impose seven separate compliance checklists on a CASP — they impose seven different demands on the same identity architecture for crypto assets onboarding (1)(4). Custody interrogates customer identity at onboarding. Operating a trading platform interrogates it at AML screening. Advice on crypto assets interrogates it at the fit-and-proper test. Reception and transmission of orders interrogates it at the cross-border transfer of crypto assets. Six or seven interrogations across the regulated services a CASP runs (1).

This article is for the compliance officer, in-house counsel, and product lead at a CASP, EMT issuer, or EU-passporting fintech who has read the regulation and has to decide what to build. Member States chose grandfathering windows of six to eighteen months under Article 143(3). Eight weeks before the cliff, the question is no longer "what is MiCA"; it is whether the document-collect-and-store identity stack a CASP chose for crypto assets onboarding in 2024 still serves a platform passporting across six NCAs by year two. The crypto industry's identity stack is what the cliff is forcing.

The 1 July 2026 cliff: what closes that day

Article 143 of the MiCA regulation defines a transitional phase running from 30 December 2024 — when Titles I, II, V, VI, and VII became applicable — to a uniform end date the regulation fixes at 1 July 2026 (1). The transitional period closes across the EU at once on that day. There is no member-state extension and no rollover for a CASP that has filed but not been authorised. ESMA's 17 April 2026 statement (ESMA75-113276571-1679) formalised what the regulator expects in the eight weeks before the cliff and the days after (3)(15). MiCA compliance for crypto assets after the cliff is a different supervisory state to compliance for crypto assets before it.

Article 143's eighteen-month maximum and Member State discretion

Article 143(3) gave each Member State discretion to allow CASPs operating under national applicable laws before 30 December 2024 to continue providing crypto asset services for crypto assets in scope until 1 July 2026 — or until granted or refused MiCA authorisation, whichever came first (1)(2). Eight Member States (FR, BG, CZ, DK, EE, HR, CY, RO) chose the full eighteen months. Ireland chose twelve months ending 29 December 2025 (4). Germany shortened to 31 December 2025 by national law; the Netherlands compressed to 1 July 2025 for VASPs (12). The cliff is uniform; the runway is not. Crypto regulation under Article 143(3) tolerates divergence at the runway but not at the cliff.

What ESMA's 17 April 2026 statement actually says

ESMA's wording is operative. "The MiCA transitional period ends uniformly across the EU on 1 July 2026, regardless of whether MiCA has been fully implemented at national level" (3)(15). The statement raises the supervisory expectation on every CASP that will not be authorised by then: ESMA "expects all unauthorised CASPs to have credible, operational and immediately executable wind-down plans, fully implemented by 1 July 2026" (3)(15). The cliff lands in the same window when stablecoin payments hit hyperscale, with Stripe Treasury, RLUSD's Title-IV EMT context, and the Israel BILS programme firming up around it. ESMA is telling CASPs that 1 July 2026 is the date by which a non-authorised CASP must already have stopped providing crypto asset services for crypto assets in scope. Migration is what the regulator wants; grandfathering is what the regulation grants until the cliff. Fenech & Fenech reads the statement as treating "failure to plan or 'last-minute' disorderly exits" as supervisory failure (15).

The three crypto assets categories MiCA defines

The MiCA framework rests on three crypto assets categories: asset referenced tokens (ARTs, Title III), e money tokens (EMTs, Title IV), and "other crypto-assets" (Title II, white-paper regime) (1)(2). Every CASP authorisation question and every passporting decision for crypto assets threads back to which of the three crypto assets categories a token falls into. ESMA's hub on markets in crypto assets enumerates the three issuer-side regimes; the EBA's hub on markets in crypto assets covers the rulebook for ARTs and EMTs.

Asset-referenced tokens, e-money tokens, and the EBA's role

Asset referenced tokens are anchored at MiCA Article 3(1) item 6 verbatim as a class of "crypto-assets purporting to maintain a stable value" by referencing another value or right, including one or more official currencies (1). E money tokens, defined at Article 3(1) item 7, reference a single fiat currency that is the legal tender of a state (1). Title IV gates EMT issuance to authorised credit institutions and e-money institutions under Directive 2009/110/EC. The Payment Services Directive context threads through the same Title IV gate. This is the architecture behind the European reaction to dollar-referenced stablecoins distributed in EU crypto markets. The EBA's hub on asset referenced tokens (ARTs) and electronic money tokens (EMTs) is explicit: issuers must hold the relevant authorisation to carry out activities in the EU (7). EBA's October 2025 opinion on the proposed reserve-liquidity RTS argued the amendments are "inconsistent with Articles 36(1)(b) and 38(1) under MiCA" and warned they "would introduce material liquidity risk, weaken alignment with the banking liquidity framework, and open scope for regulatory arbitrage" (8). Crypto asset issuers in the ART and EMT categories sit inside that motion. Issuers must publish a crypto asset white paper for the crypto assets they bring to market, operate as authorised entities, and comply with reserve-asset rules under Title III for asset referenced tokens.

Other crypto-assets and the white paper regime

The third category covers crypto assets MiCA does not classify as ARTs or EMTs. These fall under Title II and operate on the white paper regime at Articles 6 to 14 (1). A crypto asset white paper is not a marketing document — it is a regulatory disclosure carrying technical and economic information about the crypto assets in scope, the rights attached, the underlying technology, and the risks the holder is asked to consider. Crypto asset white papers must be published before any offer to the public or admission to trading on a trading platform for crypto-assets. MiCA exempts non-fungible tokens that are unique and not fungible with other crypto assets and certain utility tokens — the carve-out is narrow and does not extend to utility tokens admitted to a trading platform, and a "limited series" NFT collection that becomes fungible through fractionalisation falls back inside the regime under Article 4 and Recital 10 (1).

The seven crypto asset services regulated as CASP activities

The article's spine is Article 3(1) item 16 of the MiCA regulation, which lists each service captured under "crypto-asset service" (1). The list runs to ten lettered points (a) through (j); industry practitioners often collapse these into a colloquial seven-activity framing for compliance scoping. Operating any of the crypto asset services on a commercial basis inside EU crypto markets is regulated; operating multiple under one CASP licence requires authorisation explicitly covering each. The framework regulating crypto assets at the EU level captures the same crypto asset services regardless of how a regulator enumerates them. Regulating crypto assets through Article 3(1) item 16 is the operative mechanism the framework for crypto assets uses across crypto assets venues.

How many CASP activities — seven, eight, or ten?

The statutory source of truth is Article 3(1) item 16 of MiCA, which lists ten lettered points (a) to (j): "(a) the custody and administration of crypto-assets on behalf of clients; (b) the operation of a trading platform for crypto-assets; (c) the exchange of crypto-assets for funds; (d) the exchange of crypto-assets for other crypto-assets; (e) the execution of orders for crypto-assets on behalf of clients; (f) placing of crypto-assets; (g) the reception and transmission of orders for crypto-assets on behalf of clients; (h) providing advice on crypto-assets; (i) providing portfolio management on crypto-assets; (j) providing transfer services for crypto-assets on behalf of clients" (1). The Central Bank of Ireland and the CSSF in Luxembourg both reproduce the ten-item list under their CASP authorisation pages (4)(6); CSSF separately confirms "MiCAR became applicable to CASPs as from 30 December 2024" (6). The industry shorthand of "seven CASP activities" that this article and many practitioner guides use collapses these ten lettered points into seven functional categories — custody, trading-platform operation, exchange (treating the two exchange limbs as one), execution, placement, reception/transmission, and a combined advisory/portfolio/transfer cluster. The shorthand is a useful framing for compliance scoping, but readers should keep the regulator's ten-item list in view. A crypto asset service providers applicant is asking permission to provide one or more of the same crypto asset services regardless of how the count is presented. The framework for crypto assets MiCA establishes is the same in each case.

What each of the seven activities asks of identity

Custody and administration of crypto-assets on behalf of clients is the highest-stakes activity; the custodian holds the customer's keys, and Article 75 binds it to clear segregation and reconciliation. Operation of a trading platform — Article 3(1) item 16(b) — is the activity covered when an asset service providers (CASPs) framework brings buyers and sellers together in a system for crypto-assets. Article 3(1) item 16(e) regulates execution of orders for crypto-assets on behalf of clients. Exchange activities at Article 3(1) item 16(c) and (d) capture trading crypto assets on both sides of the order book. Placement of crypto-assets at Article 3(1) item 16(f) and reception and transmission of orders at Article 3(1) item 16(g) handle issuer-side and order-routing. Advice on crypto assets, Article 3(1) item 16(h), regulates personalised recommendations on transactions in crypto-assets; portfolio management, Article 3(1) item 16(i), regulates managing portfolios on a discretionary basis (1). Each crypto asset service interrogates customer identity at a different lifecycle point: custody at onboarding and withdrawal; trading platform at AML screening on every order beyond a threshold; advice and portfolio management trigger Article 68's fit-and-proper test. Crypto asset service providers handling multiple crypto assets activities run the same identity stack against all of them.

Title V authorisation and Title VI fit-and-proper governance

Title V of the MiCA regulation establishes the authorisation procedure for crypto asset service providers handling crypto assets; Title VI establishes the prudential, organisational, and AML obligations that bind every authorised CASP (1)(11). A CASP applicant must demonstrate AML/CFT capability at application; an authorised CASP must continue to demonstrate it under Articles 24 and 64 (11). MiCA compliance differs from 5AMLD compliance at this point — regulatory requirements run continuously, not at a single gate. MiCA compliance requires demonstrable AML/CFT capability across the full lifecycle of the crypto asset services a CASP provides for crypto assets in scope.

Authorisation procedure: Articles 59–64 in plain English

Article 59 places the authorisation requirement on every CASP intending to provide crypto asset services in the EU on a commercial basis. Jones Day's reading is the cleanest summary: "Any CASPs must obtain prior authorization from its national competent authority" (11). Article 60 vests authorisation, refusal, and withdrawal in the NCA of the Member State where the entity has its registered office (1). Articles 62 and 63 set the substantive compliance requirements — programme of operations, governance arrangements, IT systems, and capacity to manage risks. Article 62 requires applicants to evidence "robust internal controls, policies, and procedures to identify, assess and manage risks, including money laundering and terrorism financing risks" (11). Article 64 governs withdrawal where the absence of "effective systems, procedures and arrangements to detect and prevent money laundering and terrorist financing" is found (11). Compliance requirements for the crypto assets a CASP handles run from application through every supervisory inspection.

Fit-and-proper persons under Article 68 and Title V consumer protection

Article 68 makes the integrity of the CASP's management body a regulatory requirement. The operative text is precise: "The members of the management body of crypto-asset service providers shall be fit and proper and shall, in particular, not have been convicted of any offence in the field of money laundering or terrorist financing" (1). The governance structures MiCA requires under Article 68 sit alongside Title V consumer protection rules, which oblige CASPs to act in the best interests of clients, provide fair and clear information about the crypto assets they support, and publish marketing communications that are fair, not misleading, and clearly identifiable (1). Transparency on crypto assets risks sits inside the same Title V architecture; transparency obligations thread through customer onboarding because that is where the CASP discloses operative information, executes Title VI AML obligations, and binds itself to disclosure requirements governing later interactions. The consumer protection requirements MiCA places on every CASP protect consumers and users at the disclosure point. Title VI adds AML/CFT obligations on top: ongoing transaction monitoring, source of funds and source of wealth checks, suspicious-transaction reporting, and customer due diligence anchored to FATF Recommendation 10 for crypto assets — all required under the EU money laundering framework the AMLR will harmonise from 10 July 2027 (1)(10).

The national competent authority mosaic

The MiCA regulation centralises the authorisation regime at the EU level, but the national competent authority granting authorisation differs by Member State. Article 60 binds authorisation to the Member State where the CASP has its registered office (1). The Article 143(3) grandfathering choices range from six to eighteen months, producing a 30-jurisdiction mosaic of end dates any CASP passporting across the EU has to track for the crypto assets it offers (12)(13). Each NCA issues its own guidance, and the divergent regulatory frameworks of PSAN, BaKrypto, and VASP regimes that pre-date MiCA still echo into the procedural pre-examination routes the EU member states offered for crypto assets supervision.

The 30-jurisdiction grandfathering breakdown

The 30-jurisdiction breakdown practitioners use originates with ESMA's grandfathering register; Norton Rose's December 2025 read of that register, cross-checked against Freshfields, lays it out at runway-bucket granularity (12)(13). Eight EU member states chose the full eighteen months running to 1 July 2026: Bulgaria, Czechia, Denmark, Estonia, France, Croatia, Cyprus, and Romania. Seven EU member states chose twelve months running to 30 December 2025: Austria, Ireland, Greece, Spain, Italy, Slovakia, and Norway. Six EU member states chose six months running to 30 June 2025: Hungary, Netherlands, Poland, Slovenia, Latvia, and Finland. For any CASP operating across multiple jurisdictions, the result is four to six end dates and four to six NCAs to track. The regulatory frameworks across the 30-jurisdiction mosaic share the cliff but differ procedurally up to it.

What CSSF, BaFin, AMF, and Central Bank of Ireland publicly say

Germany's BaFin shortened the window to 31 December 2025 by national law, applying it to credit institutions, investment firms, e-money institutions, and regulated exchanges already operating under domestic crypto legislation (12). BaFin had pre-existing BaKrypto authorisations in place since 2020. France took the opposite view — the AMF held to the full 1 July 2026 deadline and ran a procedural pre-examination for PSAN-registered firms: "From 30 December 2024, only crypto-asset service providers (CASPs), authorised prior to carrying on their activity, may provide crypto-asset services" (5). Italy runs a dual-NCA process under the Bank of Italy and CONSOB; Freshfields reports that the Italian transitional regime, to the extent approved by the legislator, ends "at the earliest of: (A) 30 October 2025 and (B) the date on which the relevant entity has obtained (or has been refused) the authorisation to act as CASP" (12). The CSSF in Luxembourg reproduces the same ten-activity list as the regulation under its CASP authorisation page (6); the national competent authority (NCA) in Luxembourg confirms the operative compliance requirements. The Central Bank of Ireland set the Irish window at "12 months ending on 29 December 2025" with the Portal submission deadline at 2 April 2026 (4). For a CASP holding registrations in Luxembourg, Ireland, France, and Germany, the same MiCA regulation runs against four timelines, four national competent authority NCA engagements, and four routes to authorisation.

Passporting, the Travel Rule layer, and cross-border identity friction

MiCA Articles 65 and 66 establish a single-licence EU passport for authorised CASPs (1)(14). A CASP authorised in its home Member State can provide crypto asset services across the EU without re-authorisation per Member State. The passporting rights MiCA grants make it materially different from the pre-MiCA national PSAN, BaKrypto, and VASP regimes — exercising passporting rights into multiple Member States is now the default route to scale crypto asset services across EU crypto markets for crypto assets at scale. Alongside MiCA, Regulation (EU) 2023/1113 — the Transfer of Funds Regulation, often referred to as the EU's Travel Rule layer — applies to every transfer of crypto-assets between CASPs and binds the originator's CASP to attach beneficiary and originator information (9). A CASP passporting across borders interrogates customer identity at six distinct lifecycle points.

The EU passport: Articles 65–66

McCann FitzGerald's reading captures the operative position: CASPs can "provide crypto-asset services throughout the EU by passporting, either through the right of establishment (including through a branch) or through the freedom to provide services" (14). The passport is granted on the home Member State's authorisation; the host applies only consumer-protection and conduct-of-business rules locally. MiCA sits alongside existing financial services legislation including the Financial Instruments Directive (MiFID II) and the EMD; the broader financial services legislation framework treats MiCA as one layer in a stack of EU financial services acts. A CASP authorised in France, Luxembourg, or Ireland can lawfully provide crypto asset services for crypto assets across all twenty-seven Member States plus the three EEA states under one licence.

Regulation 2023/1113 (Transfer of Funds Regulation) and the Level 2 RTS pipeline

Regulation (EU) 2023/1113 applies in parallel to MiCA and binds every CASP transferring crypto assets on behalf of clients to attach originator and beneficiary information. Article 14(1) requires the originator CASP to ensure transfers include the originator's name, distributed ledger address, and crypto-asset account number, alongside the originator's "address, including the name of the country, official personal document number and customer identification number" (9). Article 14(4) requires the information "shall be submitted in advance of, or simultaneously or concurrently with, the transfer of crypto-assets and in a secure manner" (9). Every customer transfer beyond a CASP's perimeter brings Article 14 into play, and the originator CASP must already hold the information before the transfer leaves. The MiCA regulation operates at Level 1 — the regulation text itself — while ESMA, the EBA, and EIOPA produce regulatory technical standards (RTS) and implementing technical standards (ITS) as Level 2 measures adopted by the European Commission as delegated acts. The regulatory framework for crypto MiCA establishes is incomplete without the Level 2 RTS pipeline: EBA's October 2025 opinion on the proposed reserve-liquidity RTS is a concrete tell that the Level 1 + Level 2 stack will not be settled at the cliff (7)(8). The cliff is fixed; the rulebook above it is not.

The architectural wedge: identity flows under MiCA at scale

MiCA forces CASPs into a regulated authorisation regime with seven (or eight, or ten) regulated services running on top of three crypto assets categories, with twenty-seven NCAs and the Travel Rule layer of Regulation 2023/1113 binding the cross-border transfer point. The architectural question is not whether to comply. It is what identity architecture to build the compliance on. A CASP that chose a document-collect-and-store identity stack in 2024 to satisfy 5AMLD is running it against MiCA's seven-activity scope across the crypto assets ecosystem. The arithmetic does not hold. The framework for crypto assets MiCA introduces is the same whether the CASP runs it on document-collect-and-store or on attestation-based crypto assets identity infrastructure for crypto assets onboarding; the operating cost is not.

The document-collect-and-store stack: what it costs at MiCA scale

Most CASP procurement teams chose a document-collect-and-store identity vendor in 2024 because it solved a 5AMLD-era problem cleanly. The customer uploads a passport image, selfie, and address proof; the vendor runs OCR, liveness, and document-authenticity checks, returns a verified status, and stores the raw documents; the CASP keeps a copy. Under MiCA's seven-activity scope, the architecture compounds three failure modes. First, data-breach exposure scales with every interrogation across crypto assets venues — every CASP holding raw passport images for crypto assets onboarding is a target that grows with the customer base. Second, identity records are not portable across crypto asset service providers — every venue re-collects, every customer re-uploads. Third, cross-border passporting cost — onboarding customers across six Member States runs the same flow six times. Article 14(4)'s "secure manner" requirement means originator information must meet the cross-border transfer requirement at every transfer of crypto assets, not just at onboarding. The document-collect-and-store model creates fresh PII-bearing records at each interrogation across crypto assets venues — that is what the architectural choice means for crypto asset service providers.

Zero-Knowledge KYC, reusable attestations, and what MiCA forces CASPs to rebuild

The architectural alternative is a Zero-Knowledge KYC stack with reusable attestations (the term-of-art in the W3C Verifiable Credentials data model is "selective disclosure"; the cryptographic mechanism is a zero-knowledge proof). A user completes verification once at an attestation issuer; the issuer produces a cryptographically-signed attestation that the verified user has passed identity-document verification, age attestation, sanctions screening, PEP screening, criminal screening, barred-persons screening, military-personnel screening, adverse-media screening, and wallet-ownership binding; any integrating CASP queries the attestation and gets back a verified status, the document country, the age booleans, and the wallet binding. The CASP never holds the underlying ID document. The customer never re-uploads at the second, third, or fourth CASP. The regulator's requirement — evidence the customer was verified — is satisfied by the attestation rather than a stored copy. GDPR Article 5(1)(c) and Article 25 align privacy-by-design and data-minimisation with the architectural model for identity verification for crypto assets onboarding.

This is the approach we take at Verifyo. A user completes Level 1 verification once and the resulting attestation is what every integrating CASP checks. The receiving platform sees verified status, document country, age booleans, and wallet binding; it never sees the underlying ID document. The architectural consequence for crypto asset service providers operating across MiCA's seven regulated services is that the customer onboarding layer is built on a reusable attestation rather than on a copy of the customer's documents. This is the same architectural question already pressuring US compliance teams under FinCEN's effectiveness-based supervision — when the regulator interrogates the substance of the AML evidence rather than the existence of the controls, the architecture of the evidence base matters more than throughput.

Verifyo's current production tier is Level 1 – Standard KYC. Travel Rule data exchange, ongoing transaction monitoring, source of funds and source of wealth verification, KYB / business verification, and full CDD / EDD tiers are not part of Level 1 today — those capabilities sit on Verifyo's roadmap or with adjacent infrastructure. For the Travel Rule layer, data-exchange protocols sit with specialised providers; for transaction monitoring obligations Title VI prescribes, RegTech tools like Chainalysis and Elliptic occupy that space; for KYB and beneficial-ownership verification, vendors like Sumsub, Onfido, and Trulioo offer the business-side service. For the services Level 1 covers — identity verification, AML screening across six independent boolean checks, age attestation, and wallet-ownership binding — the difference is the proof-not-PII model. Verifyo's pricing is platform-side: integrating CASPs hold MTO tokens to access the API; tokens are held, not staked, burned, or locked, and remain fully owned and transferable; there is no per-verification fee. MTO token value can rise or fall. Illustrative figures in this article are not a forecast or an expected return. This article is not investment advice.

What CASPs should do in the eight weeks before 1 July 2026

The diagnostic converts to operational reality in five steps. First, audit the activities. Crypto businesses running multiple regulated services need to map which activity customers interact with at every check: onboarding, withdrawal, transfer, advisory, portfolio review. Without the map, the gap between Title V/VI obligations and what the identity stack delivers across crypto assets cannot be measured.

Second, confirm the NCA and grandfathering window. A CASP needs to confirm which Member State's NCA holds authorisation, what the window was, and whether authorisation is granted, refused, in-process, or not-yet-applied. The Central Bank of Ireland's Portal submission deadline of 2 April 2026 is behind us; CASPs that did not file have a narrower path to obtain authorisation in Ireland (4). The AMF's procedural pre-examination route is open but has its own pre-conditions (5).

Third, assess the identity architecture against the seven-activity surface. The CASP asks whether document-collect-and-store scales to the onboarding volume the seven-activity passporting surface implies. The arithmetic compounds where the CASP serves multiple activities, passports across multiple NCAs, and where Title VI AML/CFT obligations require ongoing record-keeping while Article 14 requires originator information at every cross-border transfer of crypto assets.

Fourth, confirm Title V/VI compliance gaps before the window closes. Title V authorisation and Title VI AML/CFT obligations must hold at authorisation and at every supervisory inspection. ESMA's 17 April 2026 statement is explicit that wind-down expectations apply to non-authorised CASPs operating after 1 July 2026 (3)(15). Crypto businesses approaching the cliff need to map the compliance requirements gap. MiCA compliance at CASP scale is the work of the next eight weeks.

Fifth, align with the AMLR 10 July 2027 forward arc. Regulation (EU) 2024/1624 — the AMLR — applies from 10 July 2027 and brings CASPs into the harmonised AML obliged-entity perimeter (10). Recital 14 confirms crypto-asset service providers "should also be covered by this Regulation, to mitigate any risk of misuse of crypto-assets for money laundering or terrorist financing purposes" (10). The AMLR codifies ongoing transaction monitoring at Article 25 and source of funds checks at Article 20. A CASP that aligns its Title VI architecture with AMLR's harmonised requirements now reduces transition cost in 2027.

After the cliff: what comes next

After the cliff, the seven CASP activities stop being a registration question and become an architectural one. The seven regulated services are not separate compliance silos — they are seven demands on the same identity architecture, and the decision a CASP makes before 1 July 2026 about how that architecture handles crypto assets onboarding compounds into year-one operating cost across every Member State it passports into. The MiCA regulation is the first comprehensive EU regulatory framework for crypto assets; the AMLR layer that lands twelve months after MiCA's cliff is the next. Crypto regulation for crypto assets after 1 July 2026 will not become easier. The cliff resets the supervisory baseline; what changes is which architectural choices the CASP took, and which framework for crypto assets the CASP built its architecture against.

Sources

(1) European Union. Regulation (EU) 2023/1114 (Markets in Crypto-Assets / MiCA). Articles 3, 6, 24, 59–66, 68, 75, 81, 143. 9 June 2023, OJ L 150/40. https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023R1114

(2) ESMA. Markets in Crypto-Assets Regulation (MiCA) activity hub. Last updated 24 April 2026. https://www.esma.europa.eu/esmas-activities/digital-finance-and-innovation/markets-crypto-assets-regulation-mica

(3) ESMA. Statement on the end of transitional periods under MiCA (ESMA75-113276571-1679). 17 April 2026. https://www.esma.europa.eu/sites/default/files/2026-04/ESMA75-113276571-1679_Statement_on_the_end_of_transitional_periods_under_MiCA.pdf

(4) Central Bank of Ireland. Markets in Crypto-Assets Regulation. Live; Portal submission deadline 2 April 2026. https://www.centralbank.ie/regulation/markets-in-crypto-assets-regulation

(5) Autorité des marchés financiers (AMF). The European regulation Markets in Crypto-Assets (MiCA). Last updated 29 November 2024. https://www.amf-france.org/en/news-publications/depth/mica

(6) Commission de Surveillance du Secteur Financier (CSSF). Crypto-Assets Service Providers (CASPs). Last updated 6 February 2025. https://www.cssf.lu/en/crypto-assets-service-providers-casp/

(7) European Banking Authority. Asset-Referenced and E-Money Tokens (MiCA) hub. Live. https://www.eba.europa.eu/regulation-and-policy/asset-referenced-and-e-money-tokens-mica

(8) European Banking Authority. Response on Commission's proposed changes to MiCA reserve liquidity RTS. 10 October 2025. https://www.eba.europa.eu/publications-and-media/press-releases/eba-responds-commissions-proposed-changes-technical-standards-liquidity-requirements-reserve-assets

(9) European Union. Regulation (EU) 2023/1113 (Transfer of Funds Regulation). Article 14. 9 June 2023, OJ L 150/1. https://eur-lex.europa.eu/eli/reg/2023/1113/oj/eng

(10) European Union. Regulation (EU) 2024/1624 (AMLR). Recital 14; Articles 20, 25, 26. 19 June 2024. https://eur-lex.europa.eu/eli/reg/2024/1624/oj/eng

(11) Jones Day. Crypto-Assets, CASPs, and AML/CFT Compliance: The New European Regulatory Landscape under MiCA and AMLR. July 2025. https://www.jonesday.com/en/insights/2025/07/crypto-assets-casps-and-amlcft-compliance-the-new-european-regulatory-landscape-under-mica-and-amlr

(12) Freshfields Bruckhaus Deringer. Grandfathering under MiCA: how Member States approach the transitional regime. 21 June 2024. https://technologyquotient.freshfields.com/post/102jake/grandfathering-under-mica-how-member-states-approach-the-transitional-regime

(13) Norton Rose Fulbright (Regulation Tomorrow). ESMA statement on MiCAR transitional measures. December 2025. https://www.regulationtomorrow.com/2025/12/esma-statement-on-mica-transitional-measures/

(14) McCann FitzGerald. MiCA: EU regulates crypto-assets. 12 July 2023. https://www.mccannfitzgerald.com/knowledge/financial-services-regulation/mica-eu-regulates-crypto-assets

(15) Fenech & Fenech Advocates. Get Licensed or Get Out: ESMA's Message to CASPs as the MiCA Transitional Period Looms. 24 April 2026. https://fenechlaw.com/insights/get-licensed-or-get-out-esmas-message-to-casps-as-the-mica-transitional-period-looms/