What expired
Article 143 of MiCA allowed member states to grandfather providers already operating under national law for up to 18 months. Firms providing services before 30 December 2024 could continue until authorised, refused, or until the period lapsed.
It lapsed on 1 July 2026. ESMA has been explicit that providers without authorisation after that date are expected to wind down in an orderly way, and has warned retail investors directly that not every firm they used before the deadline will be authorised after it.
The part that catches groups out
Member states did not all adopt the maximum grandfathering period, so deadlines differed by country throughout the transition. ESMA published a country-by-country list. For a group operating through several EU entities, one entity could face a materially earlier cut-off than another — and authorisation does not transfer between them.
What a user should do
Nothing dramatic, and nothing we are going to instruct. The check is narrow and verifiable: find the legal entity name in the provider’s terms, then search the relevant national competent authority’s register for it. Authorised firms appear there. That is the whole test.
Our jurisdiction pages name the regulator for each Tier 1 country and link its register.
Sources
- ESMA, Statement on the end of transitional periods under MiCA (1 Apr 2026)
- ESMA, Markets in Crypto-Assets Regulation (MiCA) (1 Jul 2026)
Not advice. Conisec reports for information only. Nothing in this article is financial, legal, tax or security advice. Verify against the primary sources linked above before acting on anything.
