Can a VASP continue operating after 1 July 2026 without a CASP license?

No. After 1 July 2026, providing crypto-asset services in the EU without a MiCA CASP authorization is illegal. The only exception is if a VASP has submitted a complete CASP application before the deadline and is still awaiting a decision — in some member states, the firm may continue operating until the NCA issues its decision. However, this depends on national grandfathering rules, which vary by country. Do not rely on this exception without legal advice specific to your jurisdiction.

Which countries had VASP registration before MiCA?

The main EU VASP registration regimes before MiCA were: (1) Estonia — EFSA (formerly FIU) issued VASP licenses from 2017; over 1,000 firms registered at peak; (2) Lithuania — Bank of Lithuania supervised crypto exchange and wallet operators; (3) Poland — KNF maintained a VASP register; (4) Czech Republic — FAÚ (financial intelligence unit) maintained a virtual asset register; (5) Slovakia — NBS supervised crypto service providers; (6) Germany — BaFin regulated crypto custody under KWG (Kryptoverwahrgeschäft). France's AMF ran a voluntary PSAN regime. Each country's transitional rules differ.

What does a VASP need to do to transition to CASP status?

The VASP-to-CASP transition requires: (1) conducting a gap analysis comparing current operations against MiCA CASP requirements; (2) uplifting capital to meet MiCA Article 67 minimum own funds (€50,000–€150,000 depending on services); (3) enhancing AML/KYC and compliance infrastructure to MiCA and DORA standards; (4) appointing required key personnel (AML Officer, MLRO, at least two independent directors); (5) preparing and submitting a full CASP authorization application to the relevant NCA; (6) resolving any legacy issues (customer complaints, AML remediation, system updates). The transition typically takes 4–8 months end to end.

Do Estonian VASP license holders automatically get a MiCA CASP license?

No. Former Estonian VASP licenses (issued by the old FIU regime) do not automatically convert to MiCA CASP authorizations. Estonia's FSA (EFSA) requires former VASPs to submit a full CASP application under MiCA. However, firms with an established compliance track record in Estonia may benefit from a slightly smoother review process if they have maintained good standing. Estonia's VASP regime was significantly tightened in 2022 — many former VASPs were already revoked. Only the surviving, clean-record firms are in a position to transition.

Is it worth applying for a CASP license in a different country than the original VASP?

Yes — and many VASPs are doing exactly this. If your original VASP registration was in a country with stricter transition requirements, higher fees, or a slower regulator, you may achieve faster and cheaper EU market access by establishing a new entity in a different member state (e.g., Lithuania or Malta) and applying for CASP authorization there. The new entity then passports back to your target markets under MiCA. Crypto License Europe regularly advises on these 'jurisdiction pivot' strategies.

What happens to VASP clients if the transition fails?

If a VASP fails to obtain CASP authorization by 1 July 2026, it must cease providing crypto-asset services in the EU. This means closing client accounts or transferring them to an authorized CASP. MiCA provides client asset protection rules: CASPs must segregate client assets, and legacy VASPs must handle wind-down in compliance with AML and consumer protection rules. Clients holding crypto assets with a failing VASP should receive advance notice and a reasonable period to transfer or withdraw assets.

✓ MiCA Regulation (EU) 2023/1114 — In force since December 2024

✓ VASP→CASP Transition Deadline: 1 July 2026

✓ Offices in Düsseldorf · Vilnius · Tallinn

✓ Free Initial Consultation

MiCA Transitional Regime

⚠ Deadline: 1 July 2026

VASP to CASP Transition Under MiCA: What You Must Do Before 1 July 2026

Frankfurt financial district — European regulatory hub where VASP-to-CASP MiCA transitions are being processed by BaFin and other EU NCAs

MiCA Regulation (EU) 2023/1114 entered into force on 30 December 2024. All crypto firms that were registered or authorized as Virtual Asset Service Providers (VASPs) under pre-MiCA national law have an 18-month transitional window — until 1 July 2026 — to obtain MiCA CASP (Crypto-Asset Service Provider) authorization. After that date, operating without a CASP license is illegal. The clock is running.

Start Your Transition Now ← MiCA CASP Overview

Transition — At a Glance

MiCA Entry into Force: 30 December 2024
Transition Deadline: 1 July 2026
Legal Basis: MiCA Article 143(3)
Who Is Affected: All EU-registered VASPs
Consequence of Failure: Must cease EU operations
Typical Transition Time: 4–8 months end to end
Our Services: Gap analysis, uplift, application

VASP vs CASP: What Changed Under MiCA?

Before MiCA, crypto service providers in the EU operated under fragmented national regimes derived from the FATF (Financial Action Task Force) definition of a Virtual Asset Service Provider (VASP). Each EU member state implemented VASP registration differently — some required full licensing (Germany: KWG), others ran lighter registration regimes (Estonia: FIU, Lithuania: Bank of Lithuania), and some had voluntary frameworks (France: AMF PSAN).

MiCA replaces all of these national VASP frameworks with a single, harmonized category: the Crypto-Asset Service Provider (CASP). A CASP is a legal entity providing one or more of the crypto-asset services listed in MiCA Annex I, following authorization by a national competent authority (NCA) under MiCA's unified licensing framework.

The key differences between the old VASP regime and the new CASP framework are significant:

Dimension	Old VASP Regime	New MiCA CASP
Legal basis	National law (per country)	EU Regulation 2023/1114 (directly applicable)
Geographic coverage	One country only	All 27 EU member states via passporting
Capital requirements	Varied (often none)	€50,000–€150,000 (MiCA Art. 67)
Governance requirements	Basic / national	2+ independent management body members, fit-and-proper
Compliance framework	AMLD-derived national rules	MiCA + DORA + AMLD6 + ESMA/EBA standards
Consumer protection	Fragmented national rules	Harmonized MiCA Title V standards
White paper obligation	Not required (usually)	Required for token issuance; CASPs must verify
Passporting	Not available	Full EU passporting (MiCA Art. 60–76)

The MiCA Transitional Regime Explained

MiCA Article 143(3) provides the transitional regime for existing VASPs. It states that crypto-asset service providers that were authorized or registered under national law before 30 December 2024 may continue providing their services until the earlier of:

1 July 2026 (the hard deadline), or
The date on which they receive a decision on their CASP authorization application

This means if you submit a CASP application and the NCA has not yet decided by 1 July 2026, you may in some member states continue operating until the decision is issued. However, this is a national discretionary rule — not all member states allow continuation pending a decision. Several have introduced stricter national transition rules.

Warning: Member States Can Shorten the Transition Period

MiCA Article 143(3) allows member states to set a shorter transition period than 18 months. Some countries have done this. If your VASP registration is in a country with a shortened transition, your deadline may be earlier than 1 July 2026. Always verify the national transition rules applicable to your specific jurisdiction. Contact Crypto License Europe for a country-specific transition analysis.

30 December 2024

MiCA Enters into Force

MiCA Regulation (EU) 2023/1114 applies to CASPs from this date. New applicants apply directly for CASP authorization. Existing VASPs enter 18-month transitional period.

Q1–Q2 2025

NCAs Open CASP Application Portals

Most EU NCAs (Bank of Lithuania, EFSA, MFSA, BaFin, CNB, NBS, KNF) opened or adapted their portals to accept MiCA CASP applications. ESMA published final RTS/ITS technical standards.

Q3 2025 (recommended)

Start of Optimal Application Window

To ensure a decision before 1 July 2026 with buffer time for queries and remediation, VASP firms should ideally have filed applications by Q3 2025. Applications filed later risk running against the deadline.

March 2026 (latest)

Last Practical Application Submission Date

To allow approximately 3–4 months of NCA review time (statutory period up to 65 working days under MiCA), the latest responsible submission date is approximately March 2026. After this, there is no guarantee of a decision before the deadline.

1 July 2026

Transitional Regime Expires — Hard Deadline

All VASPs without a CASP authorization must cease providing crypto-asset services in the EU. Only MiCA-authorized CASPs may continue operations. Non-compliant firms face sanctions, regulatory action, and reputational damage.

Country-by-Country VASP Transition Rules

The transition process differs significantly across EU member states because each country had its own VASP regime — with different requirements, registration types, and supervisory histories. Here is an overview of the key transition jurisdictions:

Country	Former VASP Regime	Transition Route	Key Consideration
🇪🇪 Estonia	FIU license (crypto exchange + wallet)	Full CASP application to EFSA required — no automatic conversion	FIU regime was tightened in 2022; many licenses revoked. Clean-record VASPs only.
🇱🇹 Lithuania	Bank of Lithuania crypto registry	Full CASP application; some firms may leverage existing compliance infrastructure	Bank of Lithuania has established MiCA application process and fintech desk.
🇩🇪 Germany	BaFin KWG Kryptoverwahrgeschäft license	BaFin-to-MiCA transition pathway; KWG crypto custody license → MiCA custody CASP	BaFin transitioned KWG licensees under simplified notification process (ended July 2025).
🇵🇱 Poland	KNF VASP register	Full CASP application to KNF	Poland's VASP register was light-touch; significant uplift required for MiCA capital and governance.
🇨🇿 Czech Republic	FAÚ virtual asset register	Full CASP application to CNB (Czech National Bank)	Regulatory supervision moves from FAÚ (intelligence unit) to CNB (financial regulator) — significant change.
🇸🇰 Slovakia	NBS crypto service supervision	Full CASP application to NBS	NBS has published transition guidance; firms with existing NBS relationship have advantage.
🇫🇷 France	AMF PSAN (voluntary registration/licensing)	PSAN holders apply for CASP authorization; licensed PSANs may have expedited path	France introduced mandatory PSAN registration in 2020; fully licensed PSANs well-positioned.
🇲🇹 Malta	MFSA VFA Act (Virtual Financial Assets Act) licenses	VFA licensees apply for CASP conversion; existing license provides foundation	Malta had Europe's first dedicated crypto law (2018). VFA Act licenses transitioning to MiCA CASP.

The 6-Step VASP to CASP Transition Process

MiCA Gap Analysis

Compare your current VASP operations, compliance framework, capital, governance, and technology against MiCA CASP requirements. Identify gaps in: minimum own funds (Art. 67), management body composition (Art. 68), AML/DORA compliance, client asset safeguarding (Art. 70), complaint handling (Art. 71), and conflict of interest policies (Art. 72). Crypto License Europe provides a structured gap analysis as the first engagement step.

Capital Uplift to MiCA Minimums

MiCA Article 67 requires minimum own funds of €50,000–€150,000 depending on services. Many legacy VASPs, especially those from registration-only regimes (Poland, Czech Republic), had no formal capital requirement. Uplift may require shareholder capital injection, restructuring, or in some cases a new entity formation with appropriate funding.

Governance and Personnel Appointments

MiCA requires a management body with at least two members, all meeting fit-and-proper criteria. Roles typically needed: AML Officer / MLRO, Chief Compliance Officer, and for significant CASPs an independent risk function. Management must have sufficient time and expertise. Existing VASP management must be assessed for MiCA fitness — remediation or replacement may be required.

Compliance Infrastructure Uplift

MiCA and DORA (Digital Operational Resilience Act) impose detailed requirements on internal controls, ICT risk management, incident reporting, business continuity, and third-party service management. Legacy VASPs typically need: enhanced AML/KYC policies to MiCA Art. 92 standard, DORA-compliant ICT risk framework, client asset segregation procedures (Art. 70), complaints handling process (Art. 71), and updated conflicts-of-interest policy (Art. 72).

Prepare and Submit CASP Application

The CASP application under MiCA Article 62 is a comprehensive submission package: business plan, program of operations, governance structure, management CVs, AML/KYC policies, ICT/DORA documentation, capital evidence, client asset safeguarding arrangements, complaints procedure, and legal opinions as required. Most NCAs have a standard form application portal. The statutory review period is up to 65 working days (approximately 3 months).

NCA Review, Q&A, and Authorization

The NCA reviews the application, may issue requests for additional information (RFIs), and conducts fit-and-proper interviews with key management. For VASPs with a strong compliance track record, this phase may be shorter. Authorization is issued in writing, specifying the crypto-asset services authorized. The CASP is then added to the ESMA CASP Register and may immediately activate passporting for other EU member states.

The Jurisdiction Pivot Strategy

Many VASPs transitioning to MiCA are using the opportunity to reconsider their home jurisdiction. If your current VASP registration is in a country with a slow regulator, high transition costs, or a complicated supervisory history, you may be better served by establishing a new EU entity and applying for CASP authorization in a more favorable jurisdiction.

This "jurisdiction pivot" strategy is legitimate and commercially rational. Under MiCA, a Lithuania-based or Malta-based CASP can passport back to your original market (including Germany, Poland, Czech Republic) without any additional license there. So if you were registered in Germany as a KWG entity but find BaFin's full MiCA process too slow or expensive, you could alternatively establish a Lithuanian UAB, obtain a CASP license from the Bank of Lithuania in 3–5 months, and passport into Germany for cross-border service provision.

When a Jurisdiction Pivot Makes Sense

A pivot is worth considering if: (1) your original VASP jurisdiction has a complex or slow transition process; (2) your compliance history in the original jurisdiction has issues that would complicate the application; (3) you want EU passporting from a jurisdiction with a faster, lower-cost authorization path; or (4) you are restructuring the group anyway (M&A, new investor, new service scope). Crypto License Europe advises on pivot feasibility analysis and handles the new-entity formation and application process.

🇱🇹

Lithuania Pivot

UAB formation in 1–2 weeks. Bank of Lithuania CASP: 3–5 months, €1,000–€2,000 gov fee. Best for cost/speed. Passporting to all 27 EU states immediately after authorization.

🇪🇪

Estonia Pivot

OÜ formation in days (e-Residency). EFSA CASP: 4–6 months, €3,300–€10,000. Strong AML reputation. Good for custody-focused and institutional CASPs.

🇲🇹

Malta Pivot

English procedures. MFSA CASP: 4–6 months, €5,000–€15,000. 5% effective tax. Best for funds, DeFi-adjacent, and firms targeting institutional EU clients.

🇮🇪

Ireland Pivot

English common law. CBI supervision. Best for US/UK-linked groups seeking EU base. Strong credibility for institutional clients and B2B CASP services.

Frequently Asked Questions

What is the VASP to CASP transition deadline?

The hard deadline is 1 July 2026. Legacy VASPs registered under national law before 30 December 2024 may operate under the transitional regime until this date. Some member states have shorter national deadlines. After 1 July 2026, only MiCA-authorized CASPs may provide crypto-asset services in the EU.

Do Estonian VASP license holders automatically become CASPs?

No. Former Estonian VASP/FIU licenses do not automatically convert to MiCA CASP authorizations. Full CASP applications must be submitted to EFSA. Estonia's FIU regime was significantly tightened in 2022, with many licenses revoked. Only firms with clean compliance records are realistic candidates for CASP authorization.

How long does the VASP-to-CASP transition take?

End-to-end, the transition typically takes 4–8 months: 4–8 weeks for gap analysis and compliance uplift, 4–8 weeks for application preparation, then the NCA review period (up to 65 working days under MiCA). Complex applications or those requiring significant remediation can take longer. Start now to have buffer before the 1 July 2026 deadline.

Can a VASP apply in a different country than its original registration?

Yes — and many VASPs are doing this. Establishing a new EU entity in a favorable jurisdiction (Lithuania, Malta, Ireland) and applying for CASP authorization there is perfectly legitimate. The new CASP can then passport back to your original market without a local license. Crypto License Europe advises on this jurisdiction pivot strategy.

What are the capital requirements for the transition?

MiCA Article 67 sets three capital tiers: €50,000 for advisory/order transmission/execution; €125,000 for exchange, portfolio management, and transfer services; €150,000 for custody and trading platform operation. Many legacy VASPs, particularly from registration-only regimes, had no formal capital requirement and will need to inject capital as part of the transition.

Author & Expert

Thomas Müller

Head of MiCA Compliance · Düsseldorf

Thomas Müller leads Crypto License Europe's MiCA transition practice from the Düsseldorf office. With deep expertise in BaFin regulation and EU financial services law, he has guided over 25 crypto firms through the VASP-to-CASP transition process. Thomas specializes in gap analysis, compliance uplift, and managing the NCA review process for complex applications across Germany, Austria, and the DACH region.

1 Jul

2026 Hard Deadline

Month Transition Window

4–8

Months to Complete Transition

EU Markets After CASP Auth

MiCA CASP compliance documents and application materials for VASP-to-CASP transition

Why Act Now

The Cost of Waiting Is High — Start Your Transition Before It's Too Late

The 1 July 2026 deadline is absolute. Unlike many regulatory deadlines that slip or get extended, MiCA's transitional regime is set by EU Regulation — it cannot be extended by national NCAs. A VASP that fails to obtain CASP authorization by that date must immediately cease providing crypto-asset services to EU clients.

The practical implication is stark: firms that wait until Q1 2026 to start their transition risk running out of time. MiCA CASP applications require 4–8 weeks of preparation and up to 65 working days (approximately 3 months) for NCA review — with no guarantee of a decision before the deadline if submitted late.

Beyond the deadline risk, early movers gain competitive advantages: first-mover positioning with EU passporting, preferred client relationships in high-growth markets, and the ability to market "MiCA Authorized CASP" status — a trust signal that matters increasingly to institutional clients, banks, and payment partners.

Crypto License Europe has managed over 40 MiCA-related engagements since December 2024. Our team in Düsseldorf, Vilnius, and Tallinn has direct experience with BaFin, the Bank of Lithuania, and EFSA — the three most active NCA desks for CASP applications. We offer a structured transition program: gap analysis → compliance uplift → application preparation → NCA liaison → authorization → passporting activation.

The 1 July 2026 Deadline Is Closer Than It Looks

Start your VASP-to-CASP transition now. Our team will assess your current compliance status, identify gaps, and manage the full application process to ensure you have your CASP authorization well before the deadline.

Get Free Transition Assessment