MiCA transitional deadlines by country

How the deadline actually works

Article 143(3) let firms that were already providing crypto-asset services under national law before 30 December 2024 keep operating under that national framework until they are authorised under MiCA, for up to 18 months. That sets a hard EU ceiling of 1 July 2026, but each member state was free to shorten the window, and many did. There is no EU-wide single date.

Your real deadline is set by the member state where you operated before 30 December 2024, not by the maximum. Several windows have already closed. Some states also set an earlier “apply by” cut-off that you had to meet to keep the benefit at all, separate from the window end.

Windows by member state

Based on the ESMA list of grandfathering periods under Article 143(3), read against the 30 December 2024 start. Dates are approximate to the day and should be confirmed with the national competent authority.

Source: ESMA list of grandfathering periods under Article 143(3). Note that Italy and Spain were widely misreported as shorter than 18 months, and Lithuania as shorter than 12; the ESMA list is the record. Poland adopted a 6-month window but has no functioning authorisation pathway as of mid-2026, so firms there are winding down or passporting in from other member states.

What happens at the cut-off

• There is no intermediate or provisional status. You are either authorised under MiCA or you must stop providing the service.
• A pending application does not extend the window. If your member state’s window closes before you are authorised, you cannot keep operating on the strength of having applied.
• Firms that were refused, or never applied, are in the same position and should run an orderly wind-down rather than assume tolerance.
• If your window has closed, options include pausing EU service, passporting in from a group entity authorised in an open jurisdiction, or completing authorisation before resuming.

Useful next pages