The MiCA transitional period ended on 1 July 2026. Every member state's grandfathering window under Article 143 has now closed, and a firm serving EU clients without CASP authorisation is, as of this month, operating unlawfully. Our view: the licensing question has flipped from "when should we apply" to "where can we still get authorised at speed", and the answer increasingly favours jurisdictions with proven throughput over theoretically attractive ones.
Two developments in the past three weeks set the tone. ESMA told unauthorised firms to wind down, and the EBA published the methodology it proposes to use when it fines token issuers. The enforcement architecture is being assembled while parts of the market are still queueing for approval.
What happens now the MiCA transitional period has ended?
ESMA's public statement of 23 June 2026 is blunt. Firms that missed authorisation by the end of their national transition must stop onboarding EU clients immediately, cease marketing to them, and execute an orderly wind-down of existing business. It also warned that reverse solicitation will be read narrowly.
National regulators are moving in step. France's AMF has confirmed the withdrawal of AUTOMATA France SAS's registration with effect from 30 June 2026, the first concrete, named example of the post-deadline clean-up. Register removals are the cheapest signal a regulator can send; expect more through the summer.
The fines regime is taking shape
On 26 June 2026 the EBA opened a consultation on the methodology for setting fines on issuers of significant asset-referenced and e-money tokens. The ceilings are steep: up to 12.5% of annual turnover for significant ART issuers and up to 10% for significant EMT issuers. A virtual public hearing takes place on 16 July 2026 and written comments close on 28 September 2026.
Because e-money tokens can only be issued by credit institutions and EMIs, this consultation matters well beyond crypto-native firms. If you are weighing EMI regimes side by side, supervisory fining power belongs on the same sheet as capital and safeguarding.
Where the authorisations are landing
The ESMA interim register, read through HELMS Advisory's tracker on 13 July 2026, shows 283 CASP authorisation records across 25 EEA countries. Germany leads on 57, ahead of France on 30, the Netherlands on 27, Malta on 22 and Cyprus on 19. The pre-deadline rush was real: 62 authorisations landed in June 2026 against 16 in May. These are private-tracker reads of a public register, so check the live ESMA files before relying on any single count.
The most instructive authorisation of the month is Ripple's. On 6 July 2026 it announced full CASP authorisation from Luxembourg's CSSF, sitting alongside the EMI licence it has held there since February 2026. Pairing both regimes in one jurisdiction is a pattern we expect more payments-adjacent firms to copy; Luxembourg's crypto entry shows why it suits that play, and you can compare CASP jurisdictions on the criteria that now matter most: realistic timelines and regulator capacity.
For firms already authorised, the post-deadline market is a distribution opportunity while competitors wind down. For everyone else the options have narrowed to a fast application in a jurisdiction that demonstrably processes them, or exit. Our State of Crypto Licensing reports track the authorisation race quarter by quarter.
Sources
- ESMA public statement on the end of the MiCA transitional period (23 June 2026)
- EBA consultation on the methodology for setting fines under MiCA (26 June 2026)
- AMF statement on the end of the MiCA transitional period (23 June 2026)
- Ripple press release on its CASP authorisation (6 July 2026)
This article is for information only and is not legal advice.