The End of Transitional Periods under MiCA and its Consequences

On 17 April 2026 ESMA released a statement regarding the end of transitional periods under the MiCA regime. In ESMA’s previous statements about supervisory convergence, transitional measures and the end of transitional periods, ESMA has consistently placed importance on authorisation, transition, and finally, client protection.

On 17 April 2026, ESMA confirmed that MiCA transitional periods across the EU will end on 1 July 2026. From that date, any entity providing crypto-asset services to EU clients without a MiCA licence will be in breach of EU law and must cease operations.

Unauthorised providers must have a credible wind-down plan in place, including advance client notice and asset transfers to authorised CASPs or self-hosted wallets. Authorised CASPs must actively onboard migrating clients while meeting AML/CFT standards, and custody arrangements with non-EU entities must be unwound. National regulators will enforce compliance strictly.

For providers unable to obtain authorisation in time, three possible options exist: seeking full MiCA authorisation, partnering with an already-licensed CASP, or executing an orderly wind-down. Consumers should verify their provider’s status on the ESMA Interim MiCA Register and act promptly if their provider is unauthorised.

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Kane Sammut Kenwood

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Legal Intern

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Justine Scerri Herrera

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Founder & Managing Partner

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More about MK Fintech Partners Ltd.

Michael Kyprianou Fintech Partners Ltd. is a Maltese company providing services in the FinTech sector. It comprises a team of dedicated experts who provide services such as Legal Advisory, Crypto Licensing, Token Issuers’ Licensing, Investment Services Licensing, and registrations of activities related to Fintech, Crypto, Blockchain & Data Protection, Investment Funds Services & Banking, Company Incorporations, and M&As.

MK Fintech Partners forms part of the Michael Kyprianou Group, a top tier international legal and advisory firm. It has established an enviable reputation as a broad-based legal practice over the years. Mainly by keeping at heart its principle to always exceed its clients’ expectations. MK has grown to become one of the largest law firms in Cyprus with offices in Nicosia, Limassol and Paphos. The MK Group’s international presence also includes fully-fledged offices in Greece (Athens and Thessaloniki), Malta (Birkirkara), Ukraine (Kiev), the United Arab Emirates (Dubai), United Kingdom (London), Israel (Tel Aviv), and Germany (Frankfurt).

The content of this article is valid  at the date of its first publication. It intends to provide a general guide to the subject matter and does not constitute legal advice. We recommend that you seek professional advice on a specific matter before acting on any information you read. For further information, contact us at MK Fintech Partners via email at contactmkfintech@kyprianou.com or by telephone +356 9905 6193.