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MiCA Licensing Wave Closes the EU Transitional Period

CryptaCount Editorial · · 5 min read
AML / KYC / LICENSING MiCA Licensing Wave Closes the EUTransitional Period

The Markets in Crypto-Assets Regulation's 18-month transitional period ended on 1 July 2026, and the final days produced a concentrated burst of authorizations across Italy, France, Spain, and Malta. For any crypto-asset service provider still operating in the EU without a license, the position is now unambiguous: ESMA has stated that firms in this position must take immediate steps to wind down their EU-facing activities.

Last-Minute Authorizations Across Key Member States

Regulators in several jurisdictions moved quickly in the final stretch, issuing approvals that pushed national totals notably higher in the hours before the deadline passed.

Italy Reaches Eight Licensed CASPs

The Bank of Italy confirmed that four companies received authorization in the final days of the transitional period, with Consob issuing the licenses in coordination with the central bank. The newly authorized firms are asset management platform Hodlie, crypto exchange Young Platform, trading platform CryptoSmart, and crypto service provider Hercle. Italy's total now stands at eight licensed CASPs.

France Adds Three, Reaching 31

The Autorité des marchés financiers authorized three additional companies: crypto investment platform Mereau Finance, blockchain infrastructure provider Iceblock, and crypto service provider Aplo. France's licensed CASP count reached 31, one of the higher national totals in the EU.

Malta and Spain Record New Entrants

In Malta, digital asset prime broker FalconX announced it had received a MiCA license. In Spain, Venga confirmed it had obtained CASP authorization. Both announcements landed within the final days of the transitional window, reflecting a pattern of firms completing the authorization process at the last practicable moment.

ESMA Register and the Broader EU Picture

By the close of the transitional period, ESMA's register of authorized CASPs covered firms across the EU and the European Economic Area. The register is the authoritative public record: compliance teams and counterparties vetting firms for onboarding or business relationships should treat it as the primary reference point. For background on how the CASP authorization framework operates and what the expiry of the transitional period means in practice, see our earlier analysis of MiCA transitional period expiry and mandatory CASP authorization.

Greece and Other Non-Issuing States

Not every member state had issued MiCA licenses by the deadline. Greece is among those yet to authorize any CASP under MiCA. The world's largest crypto exchange by trading volume applied for a license in Greece but subsequently withdrew that application, stating it would pursue authorization in a different member state. That firm remains unlicensed under MiCA as of the transition close.

ESMA's Position on Unlicensed Operators

On 23 June 2026, ESMA issued a statement directed at crypto-asset service providers that had not secured authorization by the deadline. The language was direct: those firms must take immediate steps to wind down their EU activities. There is no grace extension. The transitional provisions that allowed previously registered or notified firms to continue operating during the 18-month window have now lapsed.

For accounting firms and CFOs with clients or counterparties in this space, the practical implication is straightforward. Any firm continuing to offer crypto-asset services to EU clients without a valid MiCA authorization is operating outside the regulatory framework. That has consequences for counterparty risk assessments, AML due diligence obligations, and potentially the enforceability of contracts. Firms handling client assets or providing custody, exchange, or advisory services in scope of MiCA need to be on the ESMA register or they should not be receiving EU business. This connects directly to the ESMA clarification on MiCA white paper exemptions, which sets out the boundaries of which offerings fall within the regulation's scope in the first place.

Practical Steps for Compliance and Advisory Teams

Verify Counterparties Against the ESMA Register

The ESMA public register is the definitive source. Before onboarding a crypto-asset service provider as a counterparty, verifying their authorization status is a basic due diligence step. Firms that were operating under transitional provisions and did not complete the authorization process no longer have a compliant basis to serve EU clients.

Review Client Portfolios for Exposure

Accounting firms advising corporate clients who hold assets at, or transact through, unlicensed providers should flag this exposure now. There are both regulatory and financial risk dimensions: assets held at an unlicensed CASP may not benefit from the investor protection provisions built into MiCA, and continued use of such a provider after the deadline raises questions about a firm's own AML compliance posture. The AML risks attached to opaque or unregulated crypto channels are real, as illustrated by enforcement patterns covered in our piece on Huione Group's illicit marketplace and USDH stablecoin AML risk.

Update Internal Policies and Approved-Provider Lists

Any internal policy that references approved crypto-asset service providers needs to be updated against the current ESMA register. Firms that previously appeared on an approved list under transitional status may no longer qualify. This is not a one-time check: the register is a live document, and authorization status can change.

What the Licensing Distribution Tells Us

The concentration of last-minute approvals in a handful of jurisdictions reflects the uneven pace of national competent authority readiness across the EU. France, with 31 licensed CASPs, has processed a substantial share of applications. Italy's move to eight in a single week suggests a backlog clearing at deadline. Malta, historically an active licensing hub for crypto firms, saw at least one significant addition. Spain added a new entrant in the final hours.

Jurisdictions that have issued no MiCA licenses by the deadline present a different set of questions. Firms that had been operating under those national transitional regimes now face a more constrained path: they either need to identify a member state willing to process their application and continue operating on a cross-border basis while that application is pending, or they need to suspend EU activities. The regulatory position is not ambiguous, even if the operational path forward requires careful structuring.

Source: Cointelegraph Regulation

EUITFRGeneralEffectiveAML/KYC & Licensing

FAQ

Is the MiCA transitional period over, and what does that mean for unlicensed firms?

Yes. The 18-month transitional period under MiCA ended on 1 July 2026. Any crypto-asset service provider that has not received authorization from a national competent authority and is not listed on the ESMA CASP register no longer has a legal basis to serve EU or EEA clients. ESMA has stated publicly that such firms must take immediate steps to wind down their EU activities.

Where can firms verify whether a crypto-asset service provider holds a valid MiCA license?

The ESMA public register of authorized CASPs is the authoritative source. It covers all EU and EEA member states and is updated as new authorizations are granted or withdrawn. National competent authority websites, such as the Bank of Italy or the AMF in France, may also publish their own national lists.

Which member states issued the most MiCA licenses during the transitional period?

Based on the information available at the close of the transitional period, France had authorized 31 CASPs and Italy had reached eight. Malta and Spain also recorded additions in the final days. Some member states, including Greece, had not issued any MiCA licenses by the deadline.

What are the AML due diligence implications of using an unlicensed CASP after the transitional period?

Continuing to route transactions through or hold assets at an unlicensed provider after the transitional period creates a compliance gap. MiCA authorization carries with it AML/CFT obligations aligned with EU standards. An unlicensed provider operates outside that framework, which affects counterparty risk ratings, the quality of transaction monitoring, and a firm's own ability to demonstrate adequate AML controls to its regulator.

Can a firm headquartered outside the EU still serve EU clients if it holds no MiCA license?

MiCA applies to firms offering crypto-asset services to clients located in the EU, regardless of where the firm is incorporated. Without authorization from an EU national competent authority and a listing on the ESMA register, a non-EU firm has no compliant basis to actively market or provide in-scope services to EU clients after the transitional period closed.

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