MiCA’s transitional period closed on 1 July 2026 with roughly 244 authorised crypto-asset service providers against more than 1,200 previously registered entities — a conversion rate of about 20%. The binding constraint was never the rulebook; it was authorisation capacity at national regulators.

Article 143(3) of the Markets in Crypto-Assets Regulation gave member states discretion to grant firms already providing crypto-asset services under national law a transitional period of up to 18 months, running from 30 December 2024, as Shoosmiths set out ahead of the deadline. That clock expired on 1 July 2026, and no member state was permitted to extend it. Firms without authorisation on that date are providing services in breach of EU law. This analysis walks through the wind-down obligations the European Securities and Markets Authority (ESMA) has set out, the geography of who converted and who did not, and why enforcement is likely to be uneven.

Key facts

• 244 authorised CASPs as of June 2026, revised up from roughly 230 earlier that month — CoinDesk, 29 June 2026
• 1,200+ registered entities across the EU before the deadline, implying a conversion rate of roughly 17%-20%
• Article 143(3) simplified procedure applied only to firms already operating under a national regime as of 30 December 2024
• 1 July 2026 is the hard outer boundary — member states could shorten but never extend the transitional period
• Poland accounted for roughly 1,400 of 3,000+ pre-MiCA virtual-asset service provider registrations, over 46% of the European total
• Early-2026 register concentration: Germany 18, Netherlands 14, France 6, Malta 6 authorised CASPs
• ESMA public statement issued June 2026 instructing unauthorised firms to begin orderly wind-down immediately

Methodology and sources

This analysis draws on ESMA’s June 2026 public statement on the end of the MiCA transitional period, the ESMA interim MiCA register as reported through late June 2026, and contemporaneous reporting from Crypto Briefing covering the deadline week. Authorisation counts are point-in-time and move as national competent authorities complete files, so the 244 figure should be read as a June 2026 snapshot rather than a settled total. Pre-MiCA registration counts are less reliable still: national virtual-asset registers used differing scopes and some entities held multiple registrations, which is why published conversion rates range between 17% and 20% rather than resolving to a single number. Jurisdictional scope here is the 27 EU member states plus European Economic Area implementation where applicable. Where a figure could not be reconciled across sources, both are given.

What the rule actually says

MiCA’s transitional architecture sits in Article 143. Paragraph 3 created the so-called grandfathering route: firms lawfully providing crypto-asset services under national law before 30 December 2024 could continue doing so, in the member state that authorised them, until either they were granted or refused MiCA authorisation or the transitional period expired — whichever came first.

Two features of that drafting caused most of the difficulty. First, the transitional period was national, not European: a firm grandfathered in Poland could keep serving Polish clients but had no passport into other member states. Second, member states could shorten the window where their pre-existing framework was already broadly comparable to MiCA, which several did. The result was a patchwork of effective deadlines converging on a single hard stop.

ESMA’s June 2026 public statement set out what unauthorised firms must do from 1 July. The instruction is narrow and operational. Firms must immediately cease onboarding new clients and refrain from opening new client relationships or accounts. They must stop all marketing activity and solicitation directed at EU customers. Remaining activity is limited to actions strictly necessary to allow existing clients to sell or transfer crypto-assets, reallocate holdings, or close open positions. Custody may continue only for the period strictly required to complete an orderly exit. That is a wind-down mandate, not a grace period, and it does not permit continued service provision while an application is pending.

How three jurisdictions compare

Dimension	European Union (MiCA)	United Kingdom	United States
Framework status	In force; transition ended 1 July 2026	Consultation stage (FCA CP26/13)	Legislative — CLARITY Act not passed
Authorisation required	Yes, CASP licence, EU-wide passport	Existing AML registration; full regime pending	State money-transmitter plus federal overlay
Transitional relief	Expired; no extension permitted	Not yet triggered	Not applicable
Firms authorised	~244 as of June 2026	Registration-based, no MiCA equivalent	No single federal register
Passporting	Yes, across 27 member states	No	No — state by state
Enforcement trigger	Automatic from 1 July 2026	Consultation outcome dependent	Agency-led, case by case

Sources: ESMA register and public statement, June 2026; FCA consultation paper CP26/13; US legislative status as of July 2026. Figures are point-in-time.

The divergence creates a specific and predictable arbitrage. The EU now has the clearest rulebook and the highest barrier to entry; the UK has a lower immediate barrier but no passport and an unfinished regime; the US has neither a unified register nor a settled statute. A firm priced out of MiCA authorisation does not exit the market — it relocates its EU-facing activity offshore and relies on reverse solicitation, or it withdraws from the EU and concentrates elsewhere. Our earlier coverage of how the three rulebooks pulled apart ahead of the cliff set out the pre-deadline positions; the post-deadline reality is that the EU has raised its floor while the other two have not, which concentrates compliant activity and disperses everything else.

Poland is the clearest illustration. It hosted roughly 1,400 of more than 3,000 pre-MiCA virtual-asset registrations, over 46% of the European total, under a light-touch registration regime. Almost none of that population converted. The authorised register instead concentrated in Germany, the Netherlands, France and Malta — jurisdictions whose national competent authorities had both prior supervisory experience and the staffing to process files, a capacity gap ESMA itself flagged in its peer-review report.

What the industry is saying

“I estimate that 80% of the crypto players won’t survive after MiCA”

— Erald Ghoos, Chief Executive of OKX Europe

That estimate tracks the arithmetic closely. If 244 firms converted from a base above 1,200, roughly four in five entities that previously held some form of national registration no longer have a lawful basis to serve EU clients.

Enforcement context

The enforcement question is not whether the obligation binds — it plainly does — but who acts first and against whom. National competent authorities, not ESMA, hold direct enforcement powers over CASPs. That leaves 27 supervisors with differing capacity applying a uniform deadline.

The legal position is nonetheless unambiguous. As Lavan Thasarathakumar, Senior Adviser at Hogan Lovells, put it: “Any regulator allowing firms to continue would be deemed in breach of EU regulations.” A member state cannot quietly tolerate unauthorised activity without exposing itself to infringement proceedings, which removes the informal forbearance that softened earlier EU financial-services transitions.

Practical uncertainty remains substantial even among specialists. John Salmon, Partner at Hogan Lovells, was blunt about the near term: “None of us know what’s going to happen.” That candour is worth registering. There is no enforcement precedent under MiCA yet, no test case defining what constitutes an acceptable wind-down period, and no published guidance on how supervisors will treat firms with applications genuinely pending at the deadline.

The cost of authorisation explains much of the attrition. Patrick Gruhn, founder and Chief Executive of Perpetuals.com Ltd, described the realistic path as: “Call it 12-24 months to the first authorized trade with maybe €100k lawyer fees.” For a small venue, a two-year runway and six-figure legal spend before first revenue is not a compliance decision — it is an exit decision.

What this means for firms in scope

Exchanges and CASPs. If unauthorised, the wind-down obligations bind immediately: no new clients, no new accounts, no marketing, and activity restricted to letting existing clients exit. Custody continues only as long as strictly necessary. Firms should document the wind-down plan contemporaneously, because the evidential question in any later enforcement action will be whether the firm restricted activity promptly.

Brokers and introducing firms. Distribution relationships with unauthorised CASPs are now a live risk. Routing EU client flow to a venue without MiCA authorisation may itself constitute facilitating unauthorised service provision. Counterparty registers should be re-papered against the ESMA list rather than against national registrations, which no longer confer anything. Firms seeking their own permissions have followed the licence-acquisition route taken by Riverty in Luxembourg.

Custodians and fund managers. Where a custodian relies on a sub-custodian that failed to convert, the chain needs remediation before assets are trapped in an entity conducting an orderly exit. This is the operational risk most likely to surface first, because it is invisible until a withdrawal request fails — the same chain-of-custody exposure that drove Augustus to pursue its own clearing charter.

Legal and compliance teams. Reverse solicitation is the pressure point. MiCA permits it narrowly — a service genuinely initiated by the client at their own exclusive initiative — and it cannot be used as a general marketing workaround. Firms leaning on it should expect supervisory scrutiny of onboarding records, referral arrangements and any marketing that touches EU users.

“It will change the business landscape of crypto entities a lot”

— Mateusz Kara, Chief Executive of Morphic Financial Group

What is next

Three developments will shape the next two quarters. First, the authorised register will keep growing as pending files complete, which means the 20% conversion rate is a floor rather than a settled figure — but firms authorised after 1 July had no lawful basis to operate in the interim, and that gap is exactly where enforcement risk sits.

Second, supervisory architecture is itself in play. ESMA chair Verena Ross has told the Financial Times that the European Commission is drawing up plans to bring digital-asset, stock-exchange and clearing-house supervision under ESMA’s direct remit, away from national regulators, in service of a “more integrated and globally competitive” EU financial landscape. Centralised supervision would resolve the uneven-enforcement problem this deadline has exposed, but not quickly.

Third, the first enforcement action will function as de facto guidance. Until a national competent authority publishes a decision against a firm that continued operating, the market is working from a statutory text and a public statement rather than from applied precedent. Related divergence in how the US, EU and UK treat crypto code and sanctions suggests that applied interpretation, not drafting, is where these regimes actually separate.

TL;DR

MiCA’s transitional period ended on 1 July 2026 with roughly 244 authorised CASPs against more than 1,200 previously registered entities, a conversion rate near 20%. Unauthorised firms must immediately stop onboarding, cease marketing to EU clients and limit activity to orderly exit, with custody continuing only as long as strictly necessary. Enforcement sits with 27 national competent authorities of uneven capacity, and no member state may lawfully tolerate continued unauthorised activity. Poland, which hosted over 46% of pre-MiCA registrations, converted almost none; authorised firms concentrated in Germany, the Netherlands, France and Malta. Cost, not rules, drove the attrition.

Frequently asked questions

When did the MiCA transitional period end?

1 July 2026. Article 143(3) allowed member states to grant firms already operating under national law before 30 December 2024 a transitional period of up to 18 months. Member states could shorten that window but none could extend it beyond 1 July 2026, making it a hard EU-wide stop.

How many crypto firms received MiCA authorisation?

Approximately 244 crypto-asset service providers held MiCA authorisation as of June 2026, revised up from around 230 earlier that month. Set against more than 1,200 previously registered entities across the EU, that represents a conversion rate of roughly 17% to 20%.

What must an unauthorised CASP do now?

Per ESMA’s June 2026 public statement: immediately cease onboarding new clients, open no new accounts or client relationships, stop all marketing and solicitation to EU customers, and limit remaining activity to letting existing clients sell, transfer, reallocate or close positions. Custody may continue only for the period strictly necessary to complete an orderly exit.

Can a firm keep operating while its application is pending?

No. The transitional period ended irrespective of application status. A firm whose file was still with a national competent authority on 1 July 2026 lost its lawful basis to provide services on that date. ESMA has also indicated that late applications warrant heightened supervisory scrutiny.

Why did so few firms convert?

Cost and time rather than rule complexity. Practitioners describe a 12 to 24-month path to first authorised trade with legal fees around €100,000, which is uneconomic for smaller venues. Poland, which hosted over 46% of pre-MiCA registrations under a light-touch regime, converted almost none of that population.

Does reverse solicitation offer a workaround?

Only narrowly. MiCA permits services genuinely initiated by a client at their own exclusive initiative, but it cannot function as a general marketing exemption. Firms relying on it should expect supervisory examination of onboarding records, referral arrangements and any marketing reaching EU users.

Who enforces the deadline?

National competent authorities in each member state, not ESMA directly. That creates uneven enforcement capacity across 27 jurisdictions applying a uniform deadline, although a regulator declining to act would itself risk being in breach of EU law. Proposals to centralise supervision under ESMA are under discussion but not in force.

This article is informational analysis only and does not constitute legal, regulatory, tax, or investment advice. Regulatory frameworks change frequently and interpretation depends on facts and circumstances; primary documents and official regulator guidance always supersede summaries. Firms should consult qualified legal counsel and their relevant supervisory authority before taking any action based on the analysis above.