Legal Insights & Industry Trends

Expert discussion: MiCA after grandfathering: One framework, different realities.

ESMA has clarified that advice under MiCA may include personalised recommendations to use crypto-asset services, even where no specific crypto-asset transaction is recommended. The Q&A has practical implications for non-CASP introduction and referral models.

The transitional period under the EU Markets in Crypto-Assets Regulation (MiCA) for eligible crypto-asset service providers ended on 1 July 2026. During that period, certain providers that had been operating under applicable national regimes before 30 December 2024 could continue their activities until 1 July 2026, or until they were granted or refused MiCA authorisation, where the relevant Member State allowed such transitional treatment. This was the maximum European Union-

European Commission Opens Targeted Consultation on the Review of MiCA