MiCA's Article 143 transitional regime, the "grandfathering" period that let crypto-asset service providers (CASPs) registered under pre-existing national rules keep operating while their full authorisation was processed, has now run its course. Under the Markets in Crypto-Assets Regulation (Regulation (EU) 2023/1114), 1 July 2026 was the maximum EU-wide backstop rather than a single uniform switch: member states were free to shorten the window or not offer it at all, and many did, with some national regimes closing as early as mid-2025 and others at the end of that year. From the point each national window closed, firms generally need full CASP authorisation to offer crypto services in that market, although certain already-regulated entities such as credit institutions and investment firms may provide specified crypto-asset services under Article 60 by notifying their supervisor rather than seeking a fresh CASP licence.
Industry reporting paints a stark picture of readiness. According to coverage from CoinDesk and others, only around 244 CASPs held full authorisation around the deadline, leaving a large share of previously registered firms without one, and those reports estimate that more than 10 million users could be pushed to move to an authorised platform as unlicensed venues suspend or restrict services. These are press estimates, not figures published by the European Securities and Markets Authority (ESMA). ESMA's own interim MiCA register is the authoritative count, and it has kept moving, from roughly 200 authorised CASPs in mid-June 2026 to 294 by ESMA's mid-July update, so any single snapshot should be read as directional rather than final.
The stablecoin market has felt the change most visibly. Under MiCA, stablecoins fall into two regulated categories, e-money tokens and asset-referenced tokens, and only authorised versions of these may be offered to the public or admitted to trading on EU-regulated platforms. Tether did not seek MiCA authorisation for USDT, and as a result USDT has been removed or restricted on MiCA-licensed European exchanges, leaving authorised tokens such as Circle's USDC and EURC to occupy the regulated market. For a segment built on the assumption that the most liquid stablecoin would always be available, that shift has proved structural rather than cosmetic, and per-venue listings continue to change, so firms should confirm the current status of any token against the register.
Less visible, but arguably more consequential for compliance functions, is the identity dimension. Every transfer routed through a licensed exchange now carries full originator and beneficiary identity data under the crypto Travel Rule, a requirement set out in the EU Transfer of Funds Regulation (Regulation (EU) 2023/1113), MiCA's companion instrument, which has applied since 30 December 2024. For crypto-asset transfers it applies with no de minimis threshold, so no transaction is too small to fall within scope. In practice MiCA and the recast Transfer of Funds Regulation together pull crypto into the same identity-data and financial-crime perimeter that governs traditional payments, without the low-value carve-out that firms on other rails often rely on.
The regime is not static. The European Commission opened a targeted consultation on the review of MiCA on 20 May 2026, with responses initially due by 31 August 2026 and later extended to 30 September 2026, and its questions reach well beyond the current text, contemplating how the rules should treat tokenisation and a broader set of stablecoin arrangements. Under Article 140 of MiCA the Commission must report to the European Parliament and Council by 30 June 2027 and may, where appropriate, accompany that report with a legislative proposal, the revision the market already calls "MiCA 2." Firms that have only just cleared the authorisation bar are, in other words, already watching it move.
Why the authorisation shortfall is the real headline
The instinct is to frame this as a crypto-market disruption story: exchanges going dark, users scrambling, USDT delisted. Those are real developments, but they are symptoms of a bigger shift. The more revealing question is how many firms that once operated under national registration did not carry across to MiCA. ESMA does not publish that denominator, so the precise share is a matter of inference rather than an official statistic, but against the thousands of legacy national registrations spread across the EU a few hundred full authorisations implies that a large share did not make the transition. Whether that reflects supervisory capacity, firms choosing not to apply, or businesses falling short of the new standard remains unclear, and it is the question worth putting to Europe's competent authorities: a backlog points to pressure on supervisors, while a wave of unsuccessful or withdrawn applications suggests the regime has raised the bar exactly as intended.
Regulatory implications
For compliance teams, the immediate impact is operational rather than strategic. The Travel Rule now applies to every transfer regardless of value, making complete and accurate identity data a baseline requirement rather than a threshold obligation. Firms onboarding customers from platforms that lost authorisation should assume a higher level of scrutiny, particularly where the origin of assets or the strength of previous compliance controls is less certain. MiCA's stablecoin rules deserve the same attention: product and treasury teams should regularly check which tokens remain authorised, as that list is unlikely to stay static. More broadly, MiCA should no longer be viewed primarily as a licensing regime. Authorisation may have dominated the headlines, but day-to-day compliance will increasingly be shaped by identity, transaction monitoring and financial-crime controls, and that is where the operational burden now sits.
Sources
- Markets in Crypto-Assets Regulation (EU) 2023/1114 (MiCA), incl. Article 143 transitional regime and Article 140 review clause: eur-lex.europa.eu
- ESMA, Markets in Crypto-Assets Regulation (MiCA) page and interim register of authorised CASPs: esma.europa.eu
- ESMA, statement on MiCA transitional measures (member-state variation): esma.europa.eu
- Transfer of Funds Regulation (EU) 2023/1113 (crypto Travel Rule): eur-lex.europa.eu
- European Commission, targeted consultation on the review of MiCA (opened 20 May 2026, deadline extended to 30 September 2026): finance.ec.europa.eu
- CoinDesk, 29 June 2026 (press estimate for the CASP-authorisation and 10 million-user figures): coindesk.com
