If your platform is not authorised: CNMV and ESMA notices

A platform with no row in the CASP register is not, by that absence, described here as a fraud. It is without the authorisation the regulation requires in order to provide crypto-asset services in the Union. What that authorisation is sits in the licence guide. When the window for continuing without one closed sits in the transitional-period guide. This page is only the texts ESMA and the CNMV have addressed to anyone still operating, or still investing, outside that authorisation, and a way to use them without alarm.

Updated November 2026. Statement ESMA75-113276571-1679, of 17 April 2026, says the transitional period expires across the Union on 1 July 2026 and that, after that, providing crypto-asset services to EU clients without a MiCA licence breaches EU law. The CNMV statement of 15 June 2026 places the end on 30 June 2026 for providers that were using the period and, for the investor, on 1 July 2026. The Bank of Spain note treats the Law 10/2010 register as closed on that day.

ESMA’s statement of 17 April 2026

The statement sets out supervisory expectations at the end of the transitional periods. The central sentence is that, after 1 July 2026, any entity providing crypto-asset services to EU clients without a MiCA licence is in breach of EU law and must stop offering them. It recalls two groups that could not provide them even before that date: firms that were not providing services under national law before 30 December 2024, and so could not rely on the transitional regime, and firms active in a member state whose period had already ended before 1 July 2026.

On the exit, ESMA points back to what it had said on 4 December 2025: orderly wind-down plans, ready if authorisation does not arrive in time, without undue economic harm to clients. The example it gives is arranging the transfer of crypto-assets held for clients to an authorised CASP or to a self-hosted wallet, with prior notice. It expects that, by 1 July 2026, an unauthorised provider will have carried that plan out. It also expects authorised CASPs to manage the migration of existing clients and to onboard them under anti-money-laundering duties.

The warning to investors asks them to check that the firm is listed as authorised in ESMA’s interim MiCA register before investing or transferring funds, and to separate the authorised legal person in the Union from other companies in the same group. The statement also recalls that an entity established outside the Union may not, outside the narrow reverse-solicitation exception, provide MiCA services to EU investors or solicit them for that purpose. It notes that MiCA prohibits outsourcing custody to an entity that is not itself authorised as a CASP. How a self-hosted address is treated when a CASP is involved is in self-custody and the Travel Rule; the Travel Rule as a concept stays in the blog article.

The CNMV statement

The statement of 15 June 2026 says that on 30 June 2026 the transitional period ends for providers that had been relying on it, and that from then only providers that have obtained the required authorisation may operate in Spain. It asks a firm that will not obtain authorisation for an effective migration plan: the client should be able to move custodied crypto-assets to other addresses and funds to cash accounts, with security and anti-money-laundering measures. It also contemplates an agreement with another, authorised provider, if the client accepts the transfer and completes identification. It asks for prior, clear communication, with deadlines, and a reasonable withdrawal period. For the investor, the text places 1 July as the day from which dealing with an unauthorised entity means MiCA’s protections do not apply, and it recommends checking the ESMA and CNMV registers and, if there is no authorisation, asking for the migration plan.

The CNMV’s MiCA page repeats the same point: from 1 July 2026 only providers authorised by the CNMV or other European authorities may operate in Spain. The longer quotations and the fit with Article 143(3) are in the transitional-period guide. This page does not rewrite them.

The warnings list

The CNMV keeps a list of warned entities, with a date, a name and often a PDF. Those warnings typically say the company is not entered in the relevant CNMV register and is therefore not authorised to provide investment services or other activities under the CNMV’s supervision. That can cover investment boiler rooms that are not a crypto-asset CASP, and also names presented as crypto. The list changes. Naming here an entity from the November 2026 table would leave it stranded when the CNMV publishes the next one. The sound use is to search that page for the exact name, read the PDF, and not treat absence from the list as an authorisation: authorisation is read in CASPS.csv and at the authority, as the checklist sets out.

The reverse is also true. A CNMV warning is a supervisor’s notice about entities not on its registers. It is not, by itself, a negative row in the ESMA file, and it does not stand in for a complaint or a proceeding this page does not have in front of it. These texts do not contain a generic “resolution” against an international brand. If a later statement names a firm, cite that statement, not an inference.

A balance that is already there

1. Check the legal person, not the brand, in CASPS.csv and at the authority on the row. The pass is the checklist.
2. If there is no row, read the CNMV statement and ask in writing for the migration plan that text describes: destination addresses, cash accounts, deadlines and identification.
3. Separate a move to an authorised CASP from a move to an address whose keys you hold. ESMA’s example includes both. Self-custody is not covered by an exchange’s authorisation; the Travel Rule, when the transfer leaves a CASP, can still ask you for information.
4. Do not treat the closed Bank of Spain register as a safety net. The difference is in the guide to that register.
5. If you are looking for a profile that does exist, MiCA-licensed alternatives links some of them. It is not an instruction to move a balance, and it is not an offer.

None of this is advice on a particular contract. The statements describe supervisors’ expectations and protections that stop applying. A lawyer, or the CNMV’s investor line — the number printed on its own warnings — is the channel for a case, not this page.

Common questions