MiCA transitional period: what it is, how long it lasts, and what it means for exchanges and users

The MiCA transitional period is a time limit, not an authorisation. Regulation (EU) 2023/1114 lets some firms that were already providing crypto-asset services keep doing so for a while, while they apply — or do not apply — for authorisation as a crypto-asset service provider, a CASP. The window does not appear in ESMA’s public file. It is not a badge a brand can put on its website, and it does not travel from one country to another the way the passport does.

This note explains what Article 143(3) says, what the Spanish CNMV has published for Spain, and what that means for an exchange and for someone who leaves a balance on it. Full authorisation — who grants it, which services it covers, and how to read a row — is in the MiCA licence guide. The map of home authorities is in MiCA license by country. The subject here is only the window.

What the transitional regime is

MiCA applies directly across the Union. The CASP authorisation regime has applied since 30 December 2024. From that date, providing a crypto-asset service in the Union requires a Title V authorisation, unless the transitional rule still covers that firm in that member state. The text is on EUR-Lex.

The rule does not create a second kind of licence. A firm inside the window may continue the services it was already providing, on the terms its member state sets, until the window closes or until the authority grants or refuses authorisation, whichever is sooner. A firm that leaves the window without authorisation can no longer rely on the rule. The CNMV’s MiCA page puts it for Spain: Article 143(3) allows a transitional period of up to 18 months, and each member state decides whether to use the full length, to shorten it, or not to apply it.

Two sentences that sound alike are not alike. “We are in the transitional period” describes a national, temporary position. “We hold a MiCA licence” describes an authorisation granted to a legal entity, for named services, by the authority of its home member state. Only the second is what ESMA publishes in CASPS.csv, the file this site reads. The CSV has no column for “still in transition”.

What Article 143(3) says

Article 143(3), on the EUR-Lex text linked above, covers providers that provided their services in accordance with applicable law before 30 December 2024. Those providers may continue until 1 July 2026, or until they are granted or refused an authorisation under Article 63, whichever is sooner.

The same paragraph lets a member state disapply that regime, or shorten it, where the state considers that its national framework before 30 December 2024 is less strict than MiCA. Member states had to tell the Commission and ESMA, by 30 June 2024, whether they used that option and how long the regime would last. The date 1 July 2026 is the outer bound written into the regulation. It is not, by itself, every country’s date. Several states notified a shorter period. Those choices live in national law and in what each supervisor publishes.

Where a supervisor writes a date, the date and the document are cited. Where the source only gives a length in months, it stays in months. An invented end date is worse than none.

Who can use it

The starting point is that the firm was already providing the service, in practice, under national law, before MiCA required authorisation. The window is not an invitation to start from scratch on 31 December 2024. A firm that was not providing the service does not enter the window by deciding to provide it later.

For Spain, the CNMV spells out that starting point on the same page. Until MiCA applied, the relevant national statute was Law 10/2010 of 28 April on the prevention of money laundering and terrorist financing. Under that law, the Bank of Spain has kept, since May 2021, a register of firms that exchange virtual currency for fiat currency and that custody electronic wallets. The CNMV writes that natural and legal persons entered on that register on 30 December 2024 may continue providing the same services they were already providing, without applying for authorisation, until 1 July 2026 or until they are refused entry on the MiCA provider register, if the refusal comes first.

The same page adds a second group. A person who was, in Spain, actually providing crypto-asset services other than the exchange and custody services in Law 10/2010 — the CNMV gives portfolio management and advice as examples, which did not belong on the Bank of Spain register — may also continue those services through the window. The test the CNMV publishes is not “being on a list”. It is having provided the service in practice under the law that applied at the time. The Bank of Spain register covers part of that activity, not all of it.

The CNMV also says that Bank of Spain register does not disappear. From 30 December 2024 it remains for information, and it takes no new registrations. Looking it up can show who was on it. It cannot turn an old entry into a CASP authorisation. The Bank of Spain registers are the supervisor’s own pages. This note does not copy the census.

Passporting and national regimes

A MiCA authorisation and a transitional period do not move in the same way. A firm authorised in its home member state may provide, in other EEA states, the services it has notified. That is the passport. The authorisation does not change country: a firm whose home state is Ireland, and which notifies Spain, still holds an Irish authorisation. On this site it stays on the Ireland page as a home provider and, on the Spain page, only in the passport block.

The transitional regime does not grant that right. The CNMV says so on the page linked above: a provider from another member state may serve Spain if it has obtained a MiCA authorisation in an EU country and has notified its intention to provide services in Spain. If it is relying only on the transitional period of its home state, it may not, unless it also qualifies for Spain’s transitional period. The lengths can differ, and some countries may set no transitional period at all.

A brand that “operates in Europe while the licence is on the way” is not passported. The passport is read from the host-country column of the CSV, service by service. The transitional window is not in that column.

Spain: the dates the CNMV publishes

For Spain, this page cites three CNMV texts and one ESMA text, and it does not add a date of its own.

• The CNMV’s MiCA page. In the transitional-regime section it says the transitional period in Spain will end on 1 July 2026. In the section addressed to investors, the same site says that from 1 July 2026 only providers authorised by the CNMV or by other European authorities may operate in Spain. The link is the one above, cnmv.es.
• The CNMV’s MiCA questions and answers. The official PDF answers that in Spain the transitional period will end on 1 July 2026, recalls the Article 143(3) limit, and points to the ESMA list. The document is the CNMV MiCA FAQ.
• The CNMV statement on the end of the period. It says the transitional period will come to an end on 30 June 2026 for providers that were operating under it and that, from then on, only a provider holding the required authorisation may operate in Spain. For investors, the same text places the boundary on 1 July 2026: from that day, dealing with an unauthorised entity means the MiCA protections do not apply. It asks firms that do not expect authorisation in time to run a client-migration plan. The PDF is the CNMV statement.
• The ESMA list. The December 2024 PDF records Spain as 18 months. The document itself warns that some figures were communicated as a national authority’s expectation and that not all of them had yet been written into national law. The list page is on ESMA; the file is List of MiCA grandfathering periods. For Spain, the CNMV texts cited above are the national statement of that length, with a calendar date.

The FAQ and the MiCA page say the period ends on 1 July 2026. The statement says it ends on 30 June 2026 and that from 1 July only authorised providers operate. That is the same boundary, the turn of June into July 2026, not a date calculated here from “18 months”. This note is dated 3 November 2026, after that boundary. A notice can be replaced: open the CNMV page and the ESMA file again. This page does not cite a Spanish official-journal article. If that journal later moves the boundary, that text governs.

Other countries, without an invented calendar

The same December 2024 PDF records other lengths, not a calendar day: Germany and Lithuania, 12 months; France, Italy, Cyprus and Malta, 18; the Netherlands, 6. Italy carries a note in the document itself: entities on the Italian anti-money-laundering register, or in the same group, had to file for MiCA authorisation by 30 December 2025 to use the period. The PDF warns that some figures might not yet have been in national law. They are not converted into a date here. The check is the home authority and the current ESMA list. Country pages — Spain and the map in the by-country guide — show who has a CSV row, not who is still inside a window.

What it means for an exchange and for a user

For the firm, the window allows it to continue services it was already providing. It does not allow a wider catalogue, or advertising into another member state as if the authorisation existed. The CNMV statement asks a firm that will not be authorised in time for a migration plan: withdrawal of crypto-assets and funds, with security and anti-money-laundering safeguards, and the option of a transfer to an already authorised provider if the client agrees. A firm that already has a CSV row does not change status because others remain inside a window. The home page and the alternatives page group firms with a row. They are not a ranking, and a commercial link is not the licence.

If your provider is not in the CSV, it is not in the copy of the authorisation register that ESMA publishes and that this site mirrors. It may have been on the Bank of Spain register, it may have been inside the window, and it may have applied for authorisation without holding it yet. None of those three is a MiCA licence. From the boundary the CNMV has published for Spain, the CNMV itself tells investors they do not have the regulation’s protections if they deal with an unauthorised entity, and that they should check the ESMA and CNMV registers.

Authorisation is not insurance for the balance either: MiCA does not create a banking-style guarantee scheme. Telling “authorised” apart from “national window” avoids one mistake, and it does not turn the row into a promise about price.

How to check a specific firm

1. Open CASPS.csv. Search the commercial name and, separately, the legal name. If there is no row, that entity is not in the file of notified authorisations.
2. If there is a row, read the home member state, the competent authority, the LEI and the service codes. That is the authorisation. The passport is the host countries on each service, not the brand’s slogan.
3. If the case is Spain and there is no row, do not fill the gap with the old Bank of Spain register. The CNMV says what that register is still for. The authorisation, if it arrives, will show up in the CSV and at the CNMV.
4. Read the CNMV page and, if the statement is still up, the statement on the end of the period. This note is dated 3 November 2026. The source wins if they disagree.
5. Use the Spain page for the ES home cut and the passport block, and the licence guide for the pass over the LEI and the services. The transitional window does not add a third list on this site.

A brand whose app still opens in Spain after that boundary has not shown an authorisation. It has shown that the app opens. The row, or the absence of a row, is the fact this site can show.

Common questions