End of the MiCA transitional period: ESMA sets out its expectations of professionals and warns retail investors
On 1 July 2026, the transitional period from national regimes to the authorisation required under the MiCA Regulation will end across the European Union. On that date, any entity providing crypto-asset services to clients in the European Union without being authorised under the MICA Regulation must cease such activities. As this deadline approaches, ESMA has set out its expectations in a statement.
In view of the forthcoming expiry of the transitional periods currently in force in European Union Member States under the MiCA Regulation, the European Securities and Markets Authority (ESMA) has issued a statement clarifying its expectations.
Orderly wind-down plans for DASPs not authorised under MiCA
ESMA reiterates that digital asset services providers (DASPs) that have not obtained authorisation under MiCA must have credible and immediately executable wind-down plans in place, in line with the conduct, prudential and AML/CFT obligations imposed by MiCA.
These plans must enable an orderly exit from the market without causing undue harm to clients, for example by transferring crypto-assets to a crypto-asset services provider (CASP) authorised to provide services under MiCA or to a self-hosted wallet, with prior notice given to clients.
By 1 July 2026, any service provider not authorised to provide services under the European MiCA Regulation must have implemented its wind-down plan. For their part, authorised crypto-asset services providers (CASPs) are required to actively prepare for the migration of existing European Union clients before that date, by implementing robust onboarding processes that comply with AML/CFT requirements.
Following on from its public statement of 5 February 2026, the AMF reiterates that DASPs that are unable to continue their activities in compliance with the requirements of the MiCA Regulation from 1 July 2026 and which have not submitted an application for authorisation as a CASP should have, as of 30 March 2026, put in place an orderly wind-down plan for their activities and carry out only those operations strictly necessary to settle their affairs.
Reminder regarding non-EU entities and the role of national authorities
Entities established outside the European Union may not provide crypto-asset services to EU clients (apart from the limited exemption for reverse solicitation). Furthermore, CASPs may not outsource certain services to unauthorised firms, in particular the custody of crypto-assets.
Investor warning
ESMA is warning investors that not all current service providers will be authorised after 1 July 2026. If you are an investor, please check that your provider is listed as an authorised CASP on the AMF website. MiCA protections only apply to the legal entity authorised in the European Union and not to affiliated entities or those authorised outside the European Union. Please check carefully which entity you have contracted with. If your service provider has not been authorised as 1 July 2026 approaches, ensure you transfer your crypto-assets to an authorised CASP or a self-hosted wallet promptly.
Read more
- Statement on the End of Transitional Periods under MiCA
- The AMF reminds Digital Asset Service Providers that the transitional period allowing them to continue providing crypto-asset services in France without MiCA authorisation ends on 1 July 2026
- The European regulation Markets in Crypto-Assets (MiCA)
- Dossier épargnant : Investir dans les crypto-actifs (bitcoin, etc.) (in French only
- Orientations ESMA visant à prévenir le contournement de l’exemption de sollicitation inversée en vertu du règlement sur les marchés de crypto-actifs (MiCA) (in French Only))
