4 — Regulatory updates

MiCA Explained — Complete Guide for Crypto Businesses (2026 Update)

A practical 2026 guide to the EU Markets in Crypto-Assets Regulation: CASP authorisation, ART and EMT regimes, transitional periods, and the country-by-country path to a passportable licence.

MiCA is the European Union’s end-to-end framework for crypto-asset markets. It introduces a single Crypto-Asset Service Provider (CASP) authorisation across the EU, alongside distinct regimes for asset-referenced tokens (ART) and e-money tokens (EMT). The transitional period began running on 30 December 2024 and ends on different dates between 2026 and 2027 depending on the member state.

Who needs a MiCA authorisation

Any business providing one or more of the ten regulated CASP services to EU clients needs a CASP authorisation. The list covers custody, exchange (against fiat or against other crypto), placement, reception and transmission of orders, execution, advice, portfolio management, transfer services, operating a trading platform, and exchange of crypto-assets for crypto-assets. Stablecoin issuers are caught separately under the ART or EMT regime.

The transitional period country-by-country

Member states have set different end-dates for the transitional period that allows incumbents to keep operating while applying. Germany ends on 30 December 2025, France on 30 June 2026, Spain on 30 December 2025 with extension procedures, and Lithuania on 30 December 2025. Estonia, Czech Republic, Poland and the Netherlands run various dates between Q2 and Q4 2026. The choice of member state is no longer interchangeable.

How a CASP application works

The application file is harmonised across the EU but each NCA has its own examination style. Lithuania and the Czech Republic have established themselves as the most predictable mid-cost routes. Germany (BaFin) and France (AMF / ACPR) have the strongest credibility but materially longer review times. The Netherlands (DNB / AFM) sits between the two clusters.

What about ART and EMT?

Asset-referenced tokens (ART) and e-money tokens (EMT) are the stablecoin regimes. EMT corresponds to fiat-pegged stablecoins and is functionally close to the existing E-Money Directive. ART covers tokens referencing baskets of fiat, commodities or other crypto-assets. Capital, prudential and reserve obligations are higher for ART than for EMT.

FAQ

Can I passport a CASP authorisation to all 30 EEA states?

Yes — CASP authorisation in any EU member state passports across all 27 EU members plus the three EEA states. The home regulator remains the supervising authority.

Do I need a separate licence for a stablecoin and a CASP?

Yes if you both issue a stablecoin and provide CASP services. Issuance is governed by the ART / EMT regime; servicing is the CASP authorisation. They run in parallel.


About the author

Tomáš Novák

Senior Counsel — EU & Eastern Europe

Six years at the European Banking Authority working on MiCA technical standards and the Transfer of Funds Regulation.

Jurisdictions: Georgia · EU MiCA (cross-cutting)

Languages: English, Czech, Polish, Russian

  • LL.M. KU Leuven
  • Czech Bar
  • Former EBA Senior Policy Officer

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