CASP Transitional Period: Country-by-Country Expiry Calendar (2026)

MiCA became fully applicable on 30 December 2024, and with it the deadline that every legacy crypto operator in the EEA must plan around: the day the transitional period in their home member state expires. Markets in Crypto-Assets Regulation Article 143 lets each member state grant existing CASP-perimeter operators (registered VASPs, pre-MiCA national-licence holders) a grace period of up to 18 months — but the choice is national, the wording is divergent, and the expiry dates differ from country to country.¹^[1]

Get this calendar wrong and you discover, three months too late, that your VASP registration in Hungary expired in January 2026 while your customers thought you were still authorised. Get it right and you have a precise drop-dead date for the conversion programme: when the application file must lodge, when local-director hires must close, when the safeguarding accounts must open.

This guide tabulates the transitional period chosen by each EEA member state, identifies the shortest and longest grandfathering windows, and lays out the 9–18 month conversion programme that needs to land before whichever date applies to you. The calendar is verified against published NCA notices to the extent NCAs have published; member states still finalising their transposition are flagged as 'pending — verify directly'.

MiCA Article 143(3) is the legal basis. It allows a member state to permit operators already providing crypto-asset services under that member state's pre-MiCA national regime to continue operating without a CASP authorisation for up to 18 months from 30 December 2024 — i.e., until 1 July 2026 at the latest. Member states may opt for a shorter window, no transitional period at all, or a more bespoke runway tied to specific licence types.²^[2]

The transitional period is not a licence. It is a non-enforcement window: the NCA does not pursue authorisation breaches against existing operators during the period, but the operator is otherwise expected to comply with the substantive MiCA rulebook (governance, AML, Travel Rule, prudential capital). At the end of the period, the operator either holds a granted CASP authorisation or stops providing services to EEA residents.

The table below summarises each EEA member state's transitional period as published or confirmed by the NCA. Where the NCA has published official guidance, the date is shown explicitly; where the member state has opted for the maximum 18-month window without further specifying, the expiry is 1 July 2026; where transposition is still pending, the row is marked 'verify with NCA'.

The day after the transitional period expires, three things become true. First, the legacy national VASP/wallet-provider registration ceases to authorise the provision of crypto-asset services. Second, the operator must hold a granted MiCA CASP authorisation, an in-principle approval that the NCA has explicitly converted into operational permission, or it must stop providing services to EEA residents. Third, services provided to EEA residents without a valid authorisation become a regulatory breach immediately enforceable by the NCA.

Several NCAs (Bank of Lithuania, Central Bank of Ireland, BaFin) have published guidance that operators with a complete CASP application file lodged before the transitional expiry — and pending decision — may continue operating beyond the formal expiry until the NCA decides. Other member states (Cyprus, Malta) have signalled the same approach informally but have not published the same in writing. Plan to lodge a complete application 6–9 months before expiry, not the day before.

Conversion from a legacy VASP registration to a granted CASP authorisation is not paperwork — it is a programme spanning regulatory, legal, technology, and HR workstreams. The minimum runway is 9–12 months for a member state with a 12-month transitional period (Germany, Ireland), 12–18 months for the 1 July 2026 cluster.

• Treating conversion as paperwork. CASP authorisation requires substance — local directors, capital actually segregated, contracts with named Travel Rule and analytics vendors. Legacy VASP files do not satisfy this.

• Submitting close to the expiry. NCAs will not prioritise late-arriving files, and operating beyond expiry without a complete pending application is enforcement risk.

• Migrating to a member state with a longer window without considering substance requirements. The Bank of Lithuania has rejected applications where the entity moved from a shorter-window jurisdiction without genuine local operations.

• Assuming the legacy passport survives. National VASP registrations did not provide EEA passporting — only the granted CASP authorisation does.

• Forgetting AMLR. The AML Regulation overlays a single EU AML rulebook from 10 July 2027 — your AML programme must be drafted to AMLR standards, not just current EBA Guidelines.⁵^[3]⁶^[4]

Two possibilities. If your CASP application is complete and lodged with the NCA before the expiry, most NCAs (Bank of Lithuania, Central Bank of Ireland, BaFin published guidance) allow continued operation pending the decision. If no application is lodged, services to EEA residents on the day after expiry are a regulatory breach and trigger immediate cease-and-desist powers. Several member states have indicated they will publish public lists of operators whose transitional period has ended without authorisation — a serious correspondent-banking and reputational risk.

Technically possible, practically very hard. A simple corporate redomiciliation does not transfer the legacy authorisation under MiCA Article 143 — the new home member state only recognises the transitional regime for entities that were registered there before 30 December 2024. You would be applying as a new entrant. The Bank of Lithuania has explicitly rejected applications that attempted this without genuine local operations and substance.

Only those services already authorised or permitted under the legacy national regime. If your pre-MiCA permission covered exchange and custody but not portfolio management, the transitional period does not cover the new service — you need a fresh CASP authorisation for portfolio management before launching it. Several NCAs have flagged this as a frequent compliance gap during early-2026 reviews.

The Transfer of Funds Regulation applies from 30 December 2024 with no transitional carve-out. Even an operator inside the CASP transitional period must run a fully compliant Travel Rule capability — the €1,000 data-set rules, self-hosted wallet workflow, and 24-hour aggregation apply from day one. Failure here is a TFR breach independent of MiCA.⁷^[5]

Default to the maximum 18-month window expiring 1 July 2026 — but treat the assumption as provisional and verify with the NCA in writing. Several member states (Poland, Norway, Iceland) had not finalised guidance as of late 2025. Their dates should crystallise during 2026; build your conversion programme to the conservative end of the range.

AMLR replaces the patchwork of national AML regimes with a single EU rulebook from 10 July 2027 — and AMLA begins direct supervision of ~40 highest-risk obliged entities from 2028. A CASP that converts in 2026 must build its AML programme to AMLR standards, not the legacy 5AMLD national variants — otherwise you remediate the same programme twice within 18 months.

• MiCA Compliance Guide for CASPs: Authorisation walkthrough — capital, governance, supplier stack

• EEA vs UK vs Offshore: Where to Incorporate Your Crypto Business: Which jurisdiction maximises regulatory access and tax efficiency

• AML Compliance for Crypto Firms: What the 6AMLD requires from CASPs and VASPs

• MiCA Travel Rule Providers Compared: Notabene vs Sumsub vs Sygna vs Veriscope

The transitional period was designed to give legacy operators time. It was not designed to give them indefinite leniency. The CASPs that survive the conversion are the ones that started the programme 12 months before their expiry, hired the local executives 6 months before submission, and lodged a complete file 6–9 months before the deadline. The CASPs that don't survive are the ones that learned in February 2026 that their member state opted for a shorter window than they assumed.