Guide
MiCA grandfathering: the transitional period ended on 1 July 2026
Updated
The most common thing written about MiCA in 2025 is now out of date. The grandfathering window is closed, everywhere, and what replaced it is a simple binary: authorised, or winding down.
What Article 143(3) said
"Crypto-asset service providers that provided their services in accordance with applicable law before 30 December 2024, may continue to do so until 1 July 2026 or until they are granted or refused an authorisation pursuant to Article 63, whichever is sooner." Member states could decline to apply the regime, or shorten it, where they considered their pre-existing national framework less strict, and had to notify the Commission and ESMA by 30 June 2024 (Regulation (EU) 2023/1114).
The national periods ESMA published
| Length | States |
|---|---|
| 6 months | Latvia, Hungary, Netherlands, Poland, Slovenia, Finland |
| 9 months | Sweden |
| 12 months | Germany, Ireland, Lithuania, Austria, Slovakia, Norway |
| 18 months | Belgium, Bulgaria, Czechia, Denmark, Estonia, Greece, Spain, France, Croatia, Italy, Cyprus, Luxembourg, Malta, Portugal, Romania, Iceland, Liechtenstein |
Source: ESMA, list of grandfathering periods decided by member states under Article 143. ESMA's own caveat is worth repeating: some periods were communicated as national authorities' expectations and may not all have been written into national law at the time of publication. Several states also imposed application cut-offs to qualify at all, including 31 July 2025 in Czechia, 8 October 2025 in Bulgaria and 30 December 2025 in Italy for entities on the AML register.
What ends the window early
Two things, and both are in the text. A grant of authorisation ends it, obviously. So does a refusal: Article 143(3) says "granted or refused", so a firm whose application fails does not get the balance of the calendar to keep trading. The other transitional dates in Article 143 are separate and still live: operators of trading platforms have until 31 December 2027 to ensure a white paper exists, is notified and is published for crypto-assets admitted to trading before 30 December 2024 (Article 143(2)(b)).
What ESMA said as the window closed
In June 2026 ESMA set out its expectations for the end of the transitional period: providers without authorisation should have credible and immediately executable wind-down plans, and should have implemented them, including transferring clients' crypto-assets to an authorised provider or to self-hosted wallets. Authorised providers were expected to prepare for migrating those clients with onboarding that meets anti-money laundering requirements. ESMA also warned retail holders that not all current providers would be authorised after 1 July 2026 and told them to check the register (AMF summary of the ESMA statement, 23 June 2026).
If a provider is still serving EU clients today without an Article 63 authorisation or an Article 60 notification, the transitional argument is no longer available to it. Check the ESMA register before assuming otherwise.