MiCA Regulation Across the EU: Country Implementation Overview 2026

Q: What is the MiCA Regulation, and when does it take full effect in the EU?

Markets in Crypto Assets , or shortly MiCA , presents a regulatory authority within the European Union that oversees the development of blockchain technology and cryptocurrencies in the region. This regulatory entity aims to enhance legal transparency and clarity among crypto exchanges, stablecoin issuers, and Crypto-Asset Service Providers (CASPs) in the member countries. It took its full effect on December 30th, 2024, and extended its regulations to all the CASPs within the EU. The most crucial date on the crypto-businesses’ calendar is July 1, 2026, when the transition period will be officially over. It implies that only the companies holding the CASP license will be permitted to legally operate in the EU.

Ostap Korenytskyi

Lawyer

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Reviewer: Nick Dakhovskyi

Table of contents

What is MiCA?

Markets in Crypto-Assets Regulation (MiCA or MiCAR) is the first comprehensive regulatory framework in the European Union aimed at supervising the crypto market, including tokens, stablecoins, and service providers (CASPs).

MiCAR took shape with the goal of harmonizing how crypto-asset services are regulated across Member States. This EU-wide framework for crypto regulation aims to bring legal clarity for crypto exchanges, stablecoin issuers, and crypto-asset service providers (CASPs).

As of 2026, the majority of national legislators across the EU have already fully or partially adopted MiCA into domestic law. And yet, several other jurisdictions are still navigating the legislative adoption. This uneven implementation creates a high-stakes regulatory landscape for crypto businesses as the final, critical deadlines of the transitional period rapidly approach.

Key Dates

June 30, 2024: Stablecoin rules kicked in; issuers of asset-referenced tokens and e-money tokens become subject to MiCA obligations.
December 30, 2024: The full implementation of the new MiCA framework officially took effect within the EU. All new crypto-asset service providers (CASPs) must be fully authorized under MiCA before they can operate.
December 31, 2025: Multiple EU member states, most notably Lithuania and Germany, reached their shortened, so-called “grandfathering” period. It implies that crypto companies in these regions must now be fully compliant with MiCA to continue operations.
July 1, 2026: The final deadline for the transitional period. By this date, each CASP in any member state of the European Union must possess a full MiCA authorization or completely stop all crypto activities.

Early Adopters

Several EU jurisdictions took a proactive approach to implementing MiCA, providing crypto-asset businesses with early clarity on authorization, supervision, and compliance requirements for crypto exchanges and token issuers. This head start has allowed them to cultivate local digital asset ecosystems more rapidly than their counterparts. Below are six prime examples of Member States that moved early and proactively:

Germany

Germany successfully passed legislation, enacting its MiCA implementation law, the “FinmadiG” (Financial Market Digitalisation Act) in late 2024, thus establishing a national framework that both mirrors the EU regulation and introduces key transition provisions for local players. FinmadiG provides the legal foundation for BaFin (the Federal Financial Supervisory Authority) to supervise CASPs already licensed under existing German regimes (e.g., under the KWG, WpIG, ZAG, BörsG, or KAGB). Among the early authorized firms by BaFin is Bitpanda Asset Management GmbH (BitPanda).

Critically, Germany’s shortened transition ended on December 31, 2025, signifying that firms operating in the country must have obtained their CASP licenses under MiCA or be in the final stages of a BaFin-approved transition that ends on Jun 30, 2026.

Germany’s approach has proven pragmatic as the jurisdiction now offers one of the most technically complete transition regimes, balancing continuity for incumbents with full alignment to MiCA’s structure and supervisory architecture.

Malta

Even before MiCA, Malta had earned a reputation for boasting a comprehensive legal framework via its Virtual Financial Assets Act.

The Malta Financial Services Authority (MFSA) has already fully integrated the MiCA regulation in parallel with local laws in the form of its MiCA Rulebook.

Starting in March 2025, Malta has remained a leader in detailing the MiCA authorisation process, ongoing obligations, and governance requirements for Crypto-Asset Service Providers (CASPs) and Issuers of Asset-Referenced Tokens (ARTs). The Rulebook follows MiCA’s structure closely and introduces precise regulatory expectations on capital requirements, fit-and-proper assessments, compliance function independence, and notification of crypto-asset whitepapers.

Malta has already authorized several major companies to act as CASPS in full compliance with MiCA’s rigorous requirements. Those include the following companies:

Foris Dax Mt Limited (better known as Crypto.com);
Okcoin Europe Ltd (operating under the trade name OKX);
Zillion Bits Ltd (ZBX platform).

Netherlands

The Netherlands initially focused on AML-related registration for crypto firms. However, the Dutch authorities made an early transition to MiCA by empowering the Authority for the Financial Markets (AFM) to oversee CASP authorization.
Crucially, the AFM began accepting advance MiCA authorization applications and notifications as early as April 2024, allowing providers to secure approval ready for the regulation’s December 2024 launch.

This forward-looking stance has given Dutch-based and incoming CASPs a clear and relatively seamless path to compliance, underscoring the Netherlands’ reputation as a tech-savvy financial hub. By early 2026, the country had already strengthened its status as a proactive hub for crypto services by getting several major companies fully authorized quickly and successfully. Among the first of them was MoonPay Europe B.V., a global crypto trading platform.

Luxembourg

Long known as a European banking hub, Luxembourg passed a draft law in 2024 appointing its financial regulator, the Commission de Surveillance du Secteur Financier (CSSF), to oversee MiCA. Significantly, it granted the maximum 18-month transition for previously registered CASPs to obtain full MiCA authorization, ending on July 1, 2026. Major international exchanges like bitFlyer already operate in Luxembourg, and the extended window allows new entrants to align with MiCA while leveraging the country’s cross-border finance expertise. The CSSF’s measured approach offers clarity and time, making Luxembourg an appealing base for EU expansion.

Lithuania

Lithuania initially took the bold step of opting out of MiCA’s transitional period, meaning that any crypto-asset service provider operating in the country had to be fully MiCA-compliant by December 30, 2024. However, the country eventually confirmed a 12-month grandfathering window for existing CASPs that expired on December 31, 2025, prompting many local CASPs to accelerate their internal compliance efforts. As of today, only the most proactive and robust companies remain in the country’s compliant market, having successfully upgraded their registration to the full MiCA authorization under the oversight of the Bank of Lithuania.

Estonia

Estonia, long known for its strict AML-focused crypto licensing regime, has transitioned to a comprehensive MiCA-aligned framework through the Crypto Markets Act (CMA), now enforced by Finantsinspektsioon, Estonia’s Financial Supervisory Authority (FSA). The FSA opened the MiCA authorization process with detailed guidance on authorization for CASPs, ART, and EMT issuers, and cross-border service providers. All applicants must follow the structure of MiCA and the accompanying RTS/ITS templates, with documentation required in Estonian (or in English with a formal request). Applications are processed in phases, with clear timelines for completeness checks and substantive reviews. The new regime maintains Estonia’s high bar for governance, internal controls, and technical infrastructure, while bringing local oversight fully in line with EU standards under MiCA.

Moderate Implementers

These EU countries are broadly on schedule, using the full 18-month transition period. While they were not as aggressive as the early adopters, they still provide a stable, predictable path towards compliance until the critical 2026 deadline. Below is an overview of how the Czech Republic, Luxembourg, and Spain fit this category.

Czech Republic

The Czech authorities finalized their MiCA implementing measures in 2025, positioning the Czech National Bank (CNB) to act as a competent authority responsible for carrying out the functions and duties provided for in the MiCA Regulation in the Czech Republic. Many local crypto businesses are thus waiting on further guidance from the Czech National Bank before making comprehensive compliance changes. To benefit from the transitional regime until July 1, 2026, local crypto companies were required to submit their CASP applications by July 31, 2025. Overall, the combination of a stable financial environment and a reasonably flexible approach puts Czech providers in a decent position to adapt.

France

Thanks to the existing “PSAN” registration regime under the 2019 PACTE law, France already had robust rules for crypto-asset service providers. French authorities then updated national regulations to align with MiCA well in advance, culminating in the Autorité des Marchés Financiers (AMF). This way, the AMF has been accepting fast-track applications for the established PSANs. In 2026, France actively grants the full MiCA compliance. Its simplified authorization track now helps French-registered companies transition into full MiCA authorization, reinforcing France’s reputation as one of the EU’s most proactive crypto hubs.

Spain

Spain has taken concrete steps toward MiCA implementation, though it continues to use the full flexibility of the transitional period. The country adopted a 12-month transition, shorter than MiCA’s maximum of 18 months, allowing existing crypto providers to continue operating until December 30, 2025, without full MiCA authorization, provided they had already been registered under local AML rules before December 30, 2024.The Comisión Nacional del Mercado de Valores (CNMV), designated as the primary supervisory authority, published a detailed authorization manual and notification model for CASPs. While the CNMV has laid out clear technical standards and submission requirements in line with upcoming ESMA guidance, the extension until July 1, 2026, provides the local crypto companies with a much-needed time to meet the rigorous compliance and capital requirements of MiCA.

Lagging Group

Unlike the early adopters or moderate implementers, these countries have been slow to act or unclear in translating MiCA’s rules into actual national frameworks. This has created significant uncertainty for local crypto businesses and potential entrants, as no well-defined paths to authorization are yet in place. However, in 2026, two out of three have already cleared the legislative requirements, thus leaving only one notable outlier.

Poland

As of early 2026, Poland remains perhaps the most challenging jurisdiction in terms of MiCA compliance within the EU. In December 2025, the President of Poland vetoed the Crypto-Asset Market Act, leaving the Polish industry in a state of high uncertainty. While MiCA is directly applicable, the country has not introduced a national law aligning with the EU MiCA crypto regulation, leaving crypto service providers in Poland without a formal pathway for MiCA CASP authorization.

Despite some existing AML requirements for virtual currency businesses, the Polish draft of the MiCA-related law remains unadopted by the parliament of Poland. Additionally, no competent authority like the Polish Financial Supervision Authority (KNF) has been officially appointed to oversee MiCA implementation. Given that the legislative process in Poland typically takes at least 2–3 months, the timely implementation of MiCA into national law appears increasingly unrealistic.

As a result, both local and foreign businesses remain in regulatory limbo, unable to plan their compliance roadmap or apply for authorization under the MiCA framework, and have no clear timeline or procedure for securing a MiCA authorization. Therefore, for crypto companies in the jurisdiction, the critical July 1, 2026, deadline may become a major crisis point.

Portugal

Portugal, once praised for its crypto-friendly tax environment, hesitated to enact new laws or transitional arrangements for MiCA until just recently. In early January of 2026, Law No. 69/2025 came into force and provided the legal framework for the Bank of Portugal and the Portuguese Securities Market Commission (CMVM) to act as competent authorities in the sector.

While the country is now actively moving forwards the full MiCA authorization, the new applicants now find themselves under immerse pressure to finalize CASP applications before the July 2026 deadline.

Belgium

Similar to Portugal, Belgium has also successfully exited the lagging category in the last couple of months. Namely, the Law of December 11, 2025, came into force on January 3, 2026. The Financial Services and Markets Authority (FSMA) and the National Bank of Belgium (NBB) have now opened the application portals for the local CASPs. Despite a significant delay, Belgium now provides a clear legal basis for the crypto companies to achieve full compliance with clarity and in the shortest term possible.

Summary

MiCA has significantly transformed the EU’s regulatory landscape for digital assets, but the pace and depth of each Member State’s implementation vary considerably. As of 2026, the period of national “registrations” is officially over, and there are three major categories of market players that can be identified. In the first one, the early adopters like Germany, Malta, the Netherlands, Lithuania, France, and Estonia have already completed their primary transitions. Meanwhile, the second group of moderate implementers, including the Czech Republic, Luxembourg, and Spain, is currently processing the bulk of their local applications.

Finally, there used to be a few jurisdictions in the “lagging” group, such as Poland, Portugal, and Belgium, but only one of them still lacks a clear roadmap for MiCA authorization today. Namely, businesses seeking to operate in Poland must navigate legal uncertainty while hoping for imminent policy updates.

The most critical deadline for all the European CASPs is July 1, 2026. This date marks a full stop for the transitional period in the entire EU region. The “passporting” promise of MiCA is now already available to dozens of jurisdictions that acted early, leaving those who waited in rather a stressful race against the crucial deadline. Once authorized, the crypto businesses get to operate in an innovative, robust, unified environment across all Europe. Need guidance on how MiCA affects your crypto business? Our team of regulatory experts will help you navigate CASP licensing, whitepaper compliance, and cross-border operations today.

Frequently Asked Questions

What is the MiCA Regulation, and when does it take full effect in the EU?

Markets in Crypto Assets, or shortly MiCA, presents a regulatory authority within the European Union that oversees the development of blockchain technology and cryptocurrencies in the region. This regulatory entity aims to enhance legal transparency and clarity among crypto exchanges, stablecoin issuers, and Crypto-Asset Service Providers (CASPs) in the member countries. It took its full effect on December 30th, 2024, and extended its regulations to all the CASPs within the EU. The most crucial date on the crypto-businesses’ calendar is July 1, 2026, when the transition period will be officially over. It implies that only the companies holding the CASP license will be permitted to legally operate in the EU.

Which EU countries have fully implemented MiCA so far?

Such countries as Germany, Malta, the Netherlands, Luxembourg, Lithuania, and Estonia have already fully adopted the MiCA regulations, providing their local crypto-asset ventures with sufficient supervision, authorization, and compliance for crypto exchanges and token issuers. In early January 2026, Belgium and Portugal also joined this list. Their successful implementation of MiCA also provides these countries with internal controls and technical infrastructure while they operate in perfect alignment with the current EU standards.

What happens to crypto businesses in countries that haven’t implemented MiCA yet?

In countries that have been relatively slow in implementing MiCA regulations, such as Poland, businesses are currently in a so-called “regulatory limbo.” While they may benefit from local grandfathering rules until July 1, 2026, they cannot currently apply for the full authorization in their home country. What will be the consequences of this lack of action? Crypto businesses in these regions cannot “passport” their services across the EU member states, thus being trapped in their local markets until national governments finalize the authorization strategy.