VASP to CASP transition under MiCA: country-by-country grandfathering deadlines, July 1 2026 cliff, and what CASP authorisation requires after the transitional period ends.
Deadlines vary by Member State. Most countries had earlier deadlines (6-12 months) that have already passed. Only countries with 18-month grandfathering periods have July 1, 2026 deadline. Due to NCA processing times of 6-12 months, applications should be submitted immediately. See the official ESMA grandfathering periods list for country-specific dates.
The grandfathering provision (MiCA Article 143) allows existing VASP-registered providers to continue operating under their current national registrations until they obtain full CASP authorization. The period ends no later than July 1, 2026.
CASP authorization requires: registered EU legal entity, minimum capital (€50K-€150K depending on services), fit and proper management, AML/CFT policies, conflict of interest management, client complaint handling, business continuity plans, and custody arrangements if applicable.
You apply to the NCA (also called FSA - Financial Supervisory Authority) in your home Member State where your legal entity is registered. Examples include BaFin (Germany), AMF (France), CNMV (Spain), DNB (Netherlands), CBI (Ireland), and Finanstilsynet (Norway). See the complete list of FSAs in our glossary. Choice of NCA/FSA affects processing timeline and supervisory approach.
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