No. As of 1 July 2026, the MiCA transitional period has ended across all 27 EU member states. A national VASP registration is no longer a legal basis for providing crypto asset services to EU clients. Only firms holding full CASP authorisation under Article 63 of MiCA can operate.

ESMA confirmed in its April 2026 statement that there are no extensions and no further grace periods. Firms without authorisation must cease EU facing services, wind down in an orderly manner, or migrate their operations to an authorised structure.

That last option is where most VASPs should be looking. And it is where we come in.

What actually changed on 1 July 2026

Under Article 143(3) of MiCA, firms that were legally registered as VASPs before 30 December 2024 were allowed to keep operating while they pursued full CASP authorisation. That grandfathering clause was the grace period. It expired on 1 July 2026 and it was the hard outer limit. Several member states closed their windows even earlier.

The numbers tell the story. Before

MiCA, more than 1,200 VASP entities held national registrations across the EU. By May 2026, only around 210 had secured full CASP authorisation. That is a conversion rate under 18 percent. More than 80 percent of the market is now operating without a legal basis to serve EU clients.

Important detail many firms missed: a pending application is not authorisation. If your CASP application is still sitting with a national regulator, you are not covered. ESMA has been explicit on this in its

June 2026 public statement calling on unauthorised providers to wind down.

Which businesses need to take action?

MiCA's definition of a crypto asset service is deliberately broad. If your business falls into any of these categories and touches EU clients, you are in scope:

• Crypto exchanges and trading platforms

• OTC brokers and desks

• Wallet providers

• Custodians

• Crypto payment providers

• Stablecoin platforms

• Token issuance businesses

If you recognise your business model in that list and you do not hold CASP authorisation, the rest of this article is for you.

Does MiCA affect non-EU crypto companies?

Yes, and this is the trap catching a lot of firms right now. MiCA does not only regulate companies incorporated in the EU. It regulates the activity of serving EU clients.

If your business is based in the UK, Switzerland, Dubai, or anywhere else and you actively market to or onboard EU customers, you need a MiCA compliant structure. That applies in both B2C and B2B contexts. The only carve-out is reverse solicitation, where an EU client approaches you entirely on their own initiative. 

Regulators such as Luxembourg's CSSF have made it clear this is a narrow legal exception, not a commercial strategy. If you advertise, run campaigns, attend EU events to acquire clients, or operate EU facing marketing of any kind, reverse solicitation will not cover you.

MiCA also prohibits authorised CASPs from outsourcing or delegating core services, notably custody, to unauthorised entities. So routing EU flows through a non-EU affiliate does not solve the problem either.

The practical answer for non-EU firms that want EU revenue: get authorised, passport through a genuinely licensed group entity, or operate under a white label structure with an authorised CASP.

Why banks are closing VASP accounts right now

The banking side moved faster than most VASPs expected. Throughout the transition, banks and EMIs extended their own informal grace periods to VASP clients, essentially waiting to see who would convert to CASP status. That patience has run out.

Post 1 July, holding an account for an unauthorised crypto business is a direct compliance risk for the bank. Unauthorised activity under MiCA carries administrative fines starting at EUR 5 million and in some jurisdictions criminal liability. 

No compliance team is going to carry that exposure for a client relationship. So banks are offboarding. Accounts are being frozen, restricted, or given short notice closure timelines.

If you are a VASP without CASP authorisation, you are now fighting on two fronts. You have lost your legal basis to serve EU clients and you are losing the banking rails you need to operate at all.

What happens if you ignore MiCA?

Doing nothing is a decision, and it is the most expensive one available. Firms that continue serving EU clients without authorisation are exposed to:

• Enforcement action. Administrative fines under MiCA start at EUR 5 million for unauthorised activity. Some member states have added criminal penalties on top, including imprisonment for directors.

• Client offboarding. Authorised platforms and counterparties cannot legally deal with you, so your clients will be migrated away or forced to self-custody.

• Banking restrictions. Frozen accounts, blocked transactions, and closures with short notice periods.

• Loss of passporting. No authorisation means no access to any of the 27 member states, not just your home market.

• Regulatory investigations. National regulators are actively reviewing entities still operating on lapsed registrations, and ESMA publishes non-compliant entities in its register.

• Reputational damage. Appearing on a non-compliance list is public. Partners, PSPs, and future banking providers will find it in their first screening pass.

The common thread: every one of these gets worse with time. Enforcement is cheapest to avoid before the letter arrives.

What are the options for VASPs without CASP authorisation?

Realistically there are four paths:

1. Apply for your own CASP licence. Viable but slow and expensive. Regulators are not fast tracking late applications and you cannot legally operate while you wait.

2. Wind down EU operations. Orderly exit, client offboarding, asset transfers. ESMA expects this to already be underway if you have no authorisation.

3. Passport through a licensed group entity. Only works if a parent or affiliate holds genuine CASP authorisation with real substance. Shared branding is not enough.

4. Operates under a white label MiCA solution. Plug your business into an already authorised CASP structure and keep serving EU clients legally while you decide on your long term licensing strategy.

Here is how the four options compare:

For most operators the fourth option is the fastest route back to compliant revenue.

How Monepik helps VASPs get a white label MiCA solution

We work in the licensing and structuring layer that most VASPs never had to think about until now. Our background covers MSBs, SRO registered entities, and the full spectrum of high risk payment structures, which means we understand exactly where legacy VASP setups break under MiCA and how to rebuild them.

Here is what that looks like in practice:

White label CASP access. We connect you with authorised CASP partners so you can operate under an existing MiCA licence. Your brand stays front facing, the regulated entity sits behind it, and your EU clients stay onboarded legally.

Licensing structure review. MSB registrations, SRO memberships, and legacy VASP setups all interact differently with MiCA. We map your current structure against the new requirements and identify the fastest compliant path, whether that is white label, passporting, or a full CASP application in a suitable jurisdiction.

Banking continuity. Losing your legal basis usually means losing your accounts. We work with banks, EMIs, and PSPs that actively support authorised crypto structures, so your payment rails survive the transition.

Migration planning. Moving clients from an unauthorised entity to an authorised structure has to be done with proper onboarding and full AML/CFT compliance. We help you sequence it so you do not trip enforcement wires on the way.

What should VASPs do next?

If the deadline caught you unprepared, here is the sequence to work through this week, not this quarter:

1. Review your licensing status. Identify exactly what your entity holds today: legacy VASP registration, MSB, SRO membership, pending CASP application, or nothing.

2. Confirm whether you hold CASP authorisation. Check the ESMA interim MiCA register. If your entity is not listed as authorised, you are not covered, regardless of what your national registration says.

3. Assess banking relationships. Contact your banks and EMIs before they contact you. Find out where you stand and how much runway you have.

4. Map client migration. Know which clients are EU facing, what assets they hold, and what an orderly transfer to an authorised structure looks like.

5. Choose a compliant operating model. Own licence, group passport, white label, or wind down. Pick one deliberately. The default option, doing nothing, is unauthorised activity.

The Bottom Line

The grace period was the runway. It is gone. Every VASP still relying on a national registration is now either winding down or operating illegally, and the banks know it.

The firms that survive this transition will be the ones that moved onto authorised structures quickly instead of waiting for a fast track that was never coming.

If you are a VASP that missed the CASP deadline, talk to us. We will assess your structure, map your options, and get you operating under a compliant MiCA framework before the enforcement letters and account closures make the decision for you.

Contact Monepik to discuss your white label MiCA solution.

Frequently Asked Questions

When did the MiCA transitional period end?

1 July 2026. This was the maximum 18 month grandfathering period under Article 143(3), running from 30 December 2024. Some member states ended it earlier.

Can I keep operating if my CASP application is pending?

No. ESMA confirmed a pending application does not permit continued service. Only granted authorisation under Article 63 does.

Does MiCA apply to companies outside Europe?

Yes, if they actively serve or solicit EU clients. Non-EU firms need a MiCA compliant structure to access the EU market. The reverse solicitation exemption only covers clients who approach the firm entirely on their own initiative, and regulators interpret it narrowly.

Can UK crypto firms serve EU clients?

Not without a MiCA compliant structure. The UK sits outside MiCA, so a UK registration gives no EU access. UK firms need CASP authorisation in an EU member state, a licensed EU group entity, or a white label arrangement with an authorised CASP.

How long does CASP authorisation take?

Plan for several months at minimum. Initial completeness checks alone take 25 to 40 business days, and full assessments run considerably longer depending on the jurisdiction and application quality. There is no fast track, and you cannot legally serve EU clients while you wait.

Does MiCA replace VASP registration?

Yes. National VASP registers have been abolished as a basis for providing crypto asset services in the EU. CASP authorisation under MiCA is now the only route to legal operation.

Can I operate with multiple licences?

You only need one. A CASP authorisation from any single EU member state passports across all 27. What you cannot do is stack legacy registrations from different countries and treat them as EU coverage. They no longer count.

Why is my bank closing my VASP account?

Banks extended informal grace periods during the transition. After 1 July 2026, servicing an unauthorised crypto business is a compliance liability, so banks are offboarding VASPs that did not obtain CASP authorisation.

What is a white label MiCA solution?

An arrangement where your business operates under the CASP authorisation of a licensed partner entity, letting you serve EU clients legally without holding your own licence.